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TITLE Hearings on Institutional Accreditation. Hearingsbefore the Subcommittee on Postsecondary Education.of.the Committee 'on Education and Labor. House ofRepresentatives, Ninety-Eighth Congress, First-Session (February 8, 10, 1983).

INSTITUTION Congress of the U.S., Washington, D.C. HouseCommittee on Education and Labor.

PUB DATE Feb 83ROTE ;213p.; Some pages may not reproduce well due to small

print.PUB TYPE Legal/Legislative/Regulatory Materials (090) --

Viewpoints (120)

EDRS PRICE MF01/PC09 Plus Postagg.DESCRIPTORS *Accreditation (Institutions); *Accrediting Agencies;

Agency Role; *Eligibility; *Federal Aid; *FinancialSupport; Hearings; *Higher Education; PeerEvaluation; Position Papers; Self Evaluation(Groups)

IDENTIFIERS Congress 98th;cHigher Education Act 1965

ABSTRACTHearings on the U.S. system of accrediting colleges

are presented, with attention to the relationship betweenaccreditation and the eligibility system of the Department ofEducation. Colleges approved by accrediting agencies become eligibleto participate in federal financial aid programs, while schools thatdo not follow accrediting agency standards lose their eligibility forassistance. The Department -,has criteria and procedures to determinewhich national, regional, and specialized accrediting agencies shouldbe included on its list of recognized agencies. Accreditationtislargely a means of.conductin'g nongovernmental, peer evaluation o'feducational institutions or programs. Cases are cited in whichaccrediting agencies have used their status to advance certain endsof special interest groups. It is noted that some accredited collegeshave a loan default rate of 85 percent. Some representatives ofhigher education organizations advocate nongovernmental, voluntaryinstitutional accreditation as the best mechanism to establisheligibility for federal funds. Enclosed materials include copies of apamphlet on the governing board's role in accreditation and a bookie"-on strengthening quality in colleges. (SW)

***********************************************************************Reproductions supplied by EDRS are the best that can be made

from the original document.***********************************************************************

HEARINGS ON INSTITUTIONAL ACCREDITATION

oCO

HEARINGSBEFORE THE

SUBCOMMITTEE ON

W POSTSECONDARY EDUCATIONOF THE

COMMITTEE ON EDUCATION AND LABOR

HOJJSE OF REPRESENTATIVESNINETY- EIGHTH CONGRESS

FIRST SESSION

HEARINGS HELD IN WASHINGTON, D.C.,FEBRUARY 8, 10, 1983

Printed for the use of the Committee on Education and Labor

U.S. DEPARTMENT OF EDUCATIONNATIONAL INSTITUTE OF EDUCATION

EDUCATIONAL RESOURCES INFORMATIONCENTER (ERIC)

is document has been reproduced asreceived from the person or Organizationoriginating it.Minor changes have been made to improvereproduction quality.

Points of view or opinions stated in this document do not necessarily represent official MEposition or policy

U.S. GOVERNMENT PRINTING OFFICE

22-1110 WASHINGTON :1984

COMMITTEE ON EDUCATION AND LABOR

CARL D. PERKINS, Kentucky, ChairmanAUGUSTUS F. HAWKINS, California JOHN N. ERLENBORN, Illinois

)'JAMES M. JEFFORDS, VermontWILLIAM F. GOODLING, PennsylvaniaE. THOMAS COLEMAN, MissouriTHOMAS E. PETRI, WisconsinMARGE ROUKEMA, New JerseyLARRIPE. CRAIG, IdahoSTEVE GUNDERSON, WisconsinSTEVE BARTLETT, TexasRON PACKARD, California(Vacancy)

WILLIAM D. FORD, MichiganPHILLIP BURTON, CaliforniaJOSEPH M. GAYDOS, PennsylvaniaWILLIAM (BILL) CLAY, MissouriMARIO BIAGGI, New YorkIKE ANDREWS, North CarolinaPAUL SIMON, IllinoisGEORGE MILLER, CaliforniaAUSTIN J. MURPHY, PennsylvaniaBALTASAR CORRADA, Puerto RicoDALE E. KILDEE, MichiganPAT WILLIAMS, MontanaRAY KOGOVSEK, ColoradoHAROLD WASHINGTON, IllinoisMATTHEW G. MARTINEZ, CaliforniaMAJOR R. OWENS, New YorkFRANK HARRISON, PennsylvaniaFREDERICK C. BOUCHER, Virginia(Vacancy)

SUBCOMMITTEE ON POSTSECONDARY EDUCATION

PAUL SIMON,WILLIAM D. FORD, MichiganIKE ANDREWS, North CarolinaRAY KOGOVSEK, ColoradoFRANK HARRISON, PennsylvaniaFREDERICK C. BOUCHER, VirginiaMAJOR R. OWENS, New YorkCARL 9 PERKINS, Kentucky

tEg Officio)(Vacancy'

Illinois, ChairmanE. THOMAS COLEMAN, MissouriSTEVE GUNDERSON, WisconsinJAMES M. JEFFORDS, VermontWILLIAM F. GOODLING, PennsylvaniaTHOMAS E. PEI RI, WisconsinRON PACKARD, California

tEx Officio)

te

CONTENTS

Hearings held in Washington, D.C.: PageFebruary 8, 1983 1

February 10, 1983 91Statement of

Ambach, Gordon M.; president, University of the State of New York andCommissioner of Education, State of New York .92

Bell, Hon. Terrel H., Secretary of Education; accompanied. by EdwardElmendorf, Assistant Secretary los Postsecondary Education; and Rich-and J. Rowe, Director, Eligibility and Agency Evaluation Staff 2

Boyer, Ernest L.) president, Carnegie Foundation for the Advancement ofTeaching 23

Manning, Thurston E., director Commission on Institutions of HigherEducation 135 --

Millard, Richard, executive director, the Council on Postsecondary Ac-creditation 70

Peltason, Jack, president, American Council on Education 39Phillips, James M., executive director, accrediting commission, Associa-

tion of Independent Colleges and Schools, accompanied by RobertKline, chairman;.and William C. Clohan, Jr., general counsel 152

Sweet, Gordon W., executive director, Commission on Colleges of theSouthern Association of Colleges and Schools, accompanied by Joffre TWhisenton, associate executive secretary, Commission oti Colleges; andThomas Carpenter, president, Memphis State University 113

Prepared statements, letters, supplemental materials, etc.:Ambach, Gordon M., president, the University of the State of New York,

and commissioner of education:Letter to Chairman Simon, dated March 10, 1983. enclosing response

to questions 110Prepared statement of 96Questions for Dr. Gordon Ambach 109

Bell, Hon. T. H., Secretary of Education:Answers to questions from Secretary Bell 21Prepared statement of 6

Boyer, Ernest L, president, the Carnegie Foundation for the AdvanCe-ment of Teaching, prepared statement of 27

Manning, Thurston, E., director, Commission on Institutions of :iigherEducation North Central Association of Colleges and Schools:

Letter to Chairman Simon, dated March 2, 1983, enclosing responsesto questions 195

Prepared statement of 139Millard, Richard, director, the Council on Postsecondary Accreditation:

Executive summary of testimony 71Prepared statement of 73

Peltason, J. W.., president, American Council on Education:Letter to Chairman Simon, dated 3, 1983, enclosing responses

to questions 186Prepared statement of 41"The Board's Role in Accreditation," pamphlet entitled 45"To Strengthen Quality in Higher Education" summary, booklet enti-

tled 53Phillips, James M., executive director, Accrediting Commission, Associa-

tion of Independent Colleges agd Schools:Letter to Chairman Simon, dated March 7, 1983, enclosing responses

to questions 200

IV .ti

.

Prepared statements, letters, supplemental materials, le td.2-Continued, Phillips, James M., director, Accrediting Commission, Associa-

Page

4,,executive

tion of Independnnt;Colleges and SchoolsContinuedMemo to AICS accredited institutions and interested parties, subject,

interim Approved policy guidelines for institutional grant and loanprograms .. 178

Memo to AICS membei institutions, subject, revised accrediting crite-ria s 168

Prepared statement of"Procedures and Guidelines for Senior Collegiate Institutions Offer-

156

i.fr ing Education at the Graduate Level," article entitled 176Simdn, Hon. Paul, a Representative in Congress from the State of Illinois

and chairman, Subcommittee on Postsecondary Education:Opening statement of, February 8, 1983 e 1

Opening statement of, i'ebruary 40, 1983 91Sweet, Gordon W., executive director, Commission on Colleges of the

Southern AssoCiation of Colleges and Schools:Letter to Chairman Simon, dated March 4, 1983, enclosing responses

to questions 190Prepared statement of 117

Woosley, Hugh A., administrator for Accrediting Bureau of Health Edu-cation Schools, letter to Chairman Simon, dated February 21, 1983 204

t

V

HEARINGS ON INSTITUTIONAL ACCREDITATION

TUESDAY, FEBRUARY 8, 1983

HOUSE OF REPRESENTATIVES,SUBCOMMITTEE ONiPOSTSECONDAitY EDUCATION,

COMMITTEE ON EDUCATION 4Ni) LABOR,Washington, D.C.

Thee subcommittee met, pursuant to tall, at 9:40 d.m., in room2261, Rayburn House Office Building, Hon. Paul Simon (chairmanof the subcommittee) presiding.

Members present: Representatives Simon, Kogovsek, Owens,Coleman, Gunderson, Petri, and Packard:

Staff present: William A. Blakey; majority counsel; Maryln L.McAdam, majority legislative assistant; and John Dean, assistantminority counsel.

-Mr. SIMON. The subcommittee will come to o rder.I will enter a statement in the record on the accreditation prob-

lem. We have a situation, if I may describe it very briefly, wherethe Federal Government,in fact, accredits the accrediting agcaciesand the accrediting agencies are coming up with all kinds of veryminute details that sometimes have something to do with the qual-ity of education, and sometimes have nothing to do with the qual-ity of education.

Colleges and universities and other institutions feel compelled, inpart because of the Federal leverage here, to do what these accred-iting agencies require.

I have no specific sense of what we ought to be doing. That iswhy we have the wisdom of the witnesses ,today who can guide us.Perhaps there is nothing we should be doing irf the way of legisla-tion..Maybe it is simply a problem that we ought to recognize andwhich we can solve administratively.

Iri any event, there is no better way to start than to have theSecretary of Education appear before us, and we are pleased to wel-come you once again, Mr. Secretary.

[The opening statement of.Congressman Paul Simon follows:)OPENING STATEMENT OF IION. PAUL SIMON, A REPRESENTATIVE IN CONGRESS FROM

THE STATE OF ILLINOIS AND CHAIRMAN, SUBCOMMITTEE ON POSTSECONDARY EDUCA-TION

The Subcwnmittee on Postsecondary Education begins today two days of hearingson the subject of institutional accreditation. Institutional accreditation is very im-portant to most of us, but in many ways misunderstood. For example, no parentwould send their child to a college or university that was not gceredited, nor to anelementary or secondary school that did not receive the approval of whatever cacti-fying or accrediting agency was responsible for determining the quality of the edu-cation offered by the partltular school. What in fact, we have done is to equate "ac-creditation.' with "quality". In most insthnces that is appropriate where the school,

( I )

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college or university establishes or maintains a standard of qualitya standard ofquality that you or I would accept.

Institutional accreditation at the postsecondary level today, does not subscribe toa universally accepted standard, nor does it pretend to. A standard of quality variesfrom institution to institution and from region to region within the 50 states. Mtsince 1905, when the Carnegie Foundation for the Advancement of Teaching firstpublished a series of criteria for determining institutional participation in the Foun-dation's pension fund 'for faculty, has the academic community and'the public beenmore concerned about the issueS of quality in higher education as we are today.Those criteria provided a simple yardstick for measuring each postsecondary institu-tion.

An admission requirement of four.years of preparatory or secondary school study;A minimum of, at least, six full-time professors;A four-year course in the arts and sciences;A productive endowment of at least $200,000.I dare say that we have today 'some schools or colleges that we call "postsecon-

dary institutions" that might not meet those standards. The North Centrai*Associ-ation, which was first organizeil in Evanston, Illinois in March of 1895, may havebeen on the right track.in 1909 when it published explicit standards for higher edu-cation institutions in its.region. Again the factors to be measured were simple andgeneral: (1) a student had to have 120 hours to graduate; (2) the course work under-taken and' completed had to be acceptable at recognized graduate schools for pur-poses of pursuing an advanced degree; (3) a specific level of endowment was setforth or tax support necessary to maintain the institution's educational program; (4)library and laboratory equipment had to be "sufficient"; and (5) the constructionand maintenance of buildings had to ensure "hygenic conditions". Many Of the re-gional associations still seek to maintain high standards and I applaud them fortheir tremendous efforts. However, too little is being done to that end and too much

" to encourage, to stimulate and to evaluate" according to an institution's ownstandards. Accreditation is often a result of 'low aim"' on the part of an institution,rather than high achievement by the trustees, administration, faculty and students.Accrediting bodies. should not perpetuate the "low aim" approach, but shouldderuand more from the institution.

Self-regulation is essential to the independence and to the survival of higher edu-.cation. I believe that the Carnegie Foundation reportwhich we will discusstodayhas provided some excellent grist for a discussion that is long overdue In thehigher education community.

Importantly, from the Subcommittee's viewpoint, the expenditure of billions ofdollars in Federal funds is ,directly tied to the fact that an institution most beaccredited. Since the major portion of these funds are portable grants and loans toeligible studentsand institutional accreditation is inseparably connected to accessto large amounts of student aid funds -it is our responsibility to ensure that thesefunds are well;spent. ,

I look forward to hearing from or witnesses on these and other issues. We arepleased to welcome the Secretary of Education, who has seen this issue from severalpoints of viewas Commissioner of Education, as the top higher education officialin Utah and now as Secretary of Education. Welcome, Mr. Secretary.

STATEMENT OF HON. 'I'ERREL II. BELI, SECRETARY OF EDUCA-TION, ACCOMPANIED BY F:DWARD ELNIENDORF, ASSISTANTSECRETARY FOR POSTSECONDARY EDUCATION: AND RICHARDJ. ROWE, DIRECTOR, ELHjIBILITY AND AGENCY EVALUATIONSTA Fl"

Secretary BELL. Thank you, Mr. Chairman.If it is all right with you, I Will summarize my testimony and

submit it for the record.Mr. SIMON. Fine.Secretary BELL. That way I may not risk telling you more than

you want to know on this subject.Mr. SIMON. Your full statement will be entered in the record.Secretary The Higher Education Act of 1965, amended au-

thfrize5 a number of higher education programs to'support institu-tions and to support students in postsecondary educa.,ion.

3t.

The funding of these programs haS grown until now we are inthe realm of $7 billion, at least it was there the past fiscal year. Inorder for those institutions. and their students- to participate inthese programs, Congress has set institutional eligibility require-ments.

There are five of them, and the most prominent one and the onearound which I know the. chairman called this, meeting, is thp re-quirement that the institution must 1..)e accredited. It is because ofthis connection between eligibility and the accreditation require-ment that Federal funds are involved.

The accreditation system inour country is a peer-evaluation typeof program. We havedeveloped a system of relying on the decisionsof accrediting associations, regional, State, and some-df them inspecialized areas that are nationwide in their scope. It is out of thissystem that this Ogibility is established and as we recognize theaccrediting associations, we try to appraise their meeting the re-quirements that we feel that Congress intended that there' be rea-sonable standards of quality and that the students attending thoseinstitutions will be receiving instruction that is reasonably conymensural with what we would be expecting in our society.

We conducted a study of the effectiveness of our procedure forapproving these accrediting agencies. The Educational TestingService of Princeton, N.J., had the contract to evaluate the proce-dure that we have to see if it reliably diffetentiated between effec-tive agencies and those that wete not effective in seeing that thesestandards were met;

This study, the report given in May 1988, indicated that the pro-cedures that were being followed in the Department did reliablydifferentiate between ineffective and effective accrediting agencies.

It is important to emphasize, as you indicated, Mr. Chairman,that we do not accredit institutions, we recognize agencies that arereliable authorities for accreditation and we think that our proce-duie for recognition has been validated by the study that I just re-.ferred to.

Institutions that fail to :adhere to the standards that are set bytheir accrediting bodies lose their eligibility for Federal financialassistance. In my testimbny, I go into a little\detail of the history ofaccreditation. It has been in existence sincb, the late 1980's and

sbecame much more prominent in the early 1900 .

We have specialized types of accrediting bodies like those for lawand medicine, and MBA programs are accredited by the nationalorganization that accredits collegiate schools and busitNess. Thenwe have general type of entities, regional organization that ac-credit an entire institution.

I might point out, Mr. Chairmbn, that we publish a list of thenationally recognized accrediting bodies which is periodically' pub-lished in the Federal Register. This procedure has been in exist-ence now for about 30 years and there are 15 different pieces oflegislation that we have identified, I will not go into them, that re-quire accreditation standing in order to participate.

There are also 40 separate statutory references.to the Secretary'slist of approved agencies. They involve the prograryis, not only ofthe Department of Education, but a total of 10 Federal agencies,other departments and independent agencies in the Government.

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.4-I might indicate that there are alternatives to accreditation andthe qualifying steps for that. An institution can be approved if theycan be certried by three other fully accredited 'institutions. Theseinstitutions certify that the institution's credits will be accepted onthe same basis as credits accepted from fully accredited institu-tions.

Oneis more detail in it, but this is an alternative approach.

One of the problems faced by a newly established institution is to.qualify and to have a means of participation in this.

We currently recognize 47 organizations as reliable accreditingbodies and a,s indicated in my testimony, there are 77 componentsof those 47 .organizations. This includes some 13 commissions thatare units of the 6 regional' associations and then there are 64 otherbodies .of national scope that can be identified or characterized asinstitutional, specialized, or a combination of those 2 types dl' orga-nizations..

Some State education agencies have apprOval, the New YorkState Board of Regents is the .oldest of that group, and they havebeen designated by the Secretary as a nationally recognized accred-iting body.

We should emphasize that the commissions of the regional asso-ciations and the national accrediting agencies and associations donot have legal control over these institutions or the programs.They do not have governing status, but the method of peer evalva-tion of these educational institutions where a group of visiting ex-perts are selected- by the accrediting body to visit the campus andto review materials that are reported and so on. This is involved ina voluntary procedure of accreditation.

Most of the personnel that serve on these accrediting bodies, andmost of us who have worked in education have had the experiencein having the assignment to serve on these bodies, render theirservices without charge. It is sort of done as a public service. ,

These accreditation 'teams come on a campus and review thequality of the institution's offerings and then make a ecommendation about 'whether or not it ought to be approved.

',think before I conclude my comments, Mr. Chairman, I oughtto discuss for just a minute our National Advisory Committee. Itwas established by the U.S. Commissioner of Education in 1968 toprovide advice on accreditation, and institutional eligibility. It waschartered by the old Department of HEW. It was established sothat the Commissioner could receive input from the distinguishededucators and experienced persons in academe who had a feel forthe need to preserve academic freedom and institutional autonomyat the same time that we carried out the mandate from Congressthat we assure that there is reasonable quality.

Our Advisory Committee on Accreditation and Institutional Eli-gibility became established in the legislation, as you know, Mr.Chairman, in the eduction amendments of 1980. The committee iscomposed of 15 persoith that are appointed for 3-year terms. Imight indicate that the current chairman is Dr. Tim Healy. FatherHealy is the president of GeorgetoWri University.

We think we have a very outstanding and prestigious groupwhich meet a.nd review the petitions of those accrediting agencies.They receive a petition from an agency that wants to be on the

c

Secretary's approved list and they review them carefully in deter-mining what recommendation to make to the Secretary.

We rely heavily on that advice in making our decisions. Theyalso advise us on wliat criteria we ought to establish and whatchanges ought to be made. Since they are active in higher educa-tion, they are in touch with new trends and new developments andthey do a very good job in/helping usland advising us so that we donot lose sight of the reality of academe and what this responsibilityis all about.

We have periodic evaluations once an accrediting agency, is ap-proved. They are approved for a period of time. The advisory com-mittee advises us on how long the approval should be and then therecognized agencies are reviewed periodically. I would not want toleave the impression that once you are approved, you are on thelist forever.

. The recent Carnegie report entitled "The Control of the Campus"'is avery timely publication. It contains a number of recommenda-tions that we think are worthy of our concern and r have askedthis National Advisory Committee, under the leadership of Dr. TimHealy,.to carefully analyze dais Carnegie report and to make rec-oinmendations to me concerning any changes that they mightdeem to be necessary in view of the report.

When that review has been completed, Mr. Chairman, we will bepleased to submit our findings, to your subcommittee and, asalways, we are anxious to receive your advice and input.

I would'like, Mr. Chairman, to introduce my colleagues here atthe table, Dr. Ed Elmendorf is Asgistant Secretary for Postsecon-dary Education; and working under him is Dick Rowe, Director ofthe Eligibility and Agency Evaluation Staff. I am pleased to haveboth Mr. Rowe and Dr. Elmendorf here and they are here becauseI am confident that if you or other comitteesmembers ask me anyquestions I cannot answer, I can pass the buck over to them. I hopethat they do not prove me false in making that statement.

Thank you very much, Mr. Chairman, and it is a pleasure ahalways to appear here before you.

[The prepared statement or Secretary Bell follows:1

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PREPARED STATEMENT OF T. H. BELL, SECRETARY OF EDUCATION, U.S. DEPARTMENT OFEDUCATION -

Thank you for the opportunity to appear before the Committee to discuss

the relationship between the Department's eligibility system and

accreditation.

The Higher Education Act of 1965. as amended, currently authorizes a0

number of programs which support institutions of postsecondary educa-

tion. Federal funding for these Education Department programs grew to a

total of approximately seven billion dollars this past fiscal year, most

of which is .in the form of student financial assistance.

In order for either institutions or students to participate in these

programs of Federal assistance, Congress has set certain standards for

institutional eligibility. These are five in number. One of them, and

perhaps the linch-pin of the five is - although the statutory language

also provides some alternatives - that the institution be accredited by a

nationally recognized accrediting agency.

It is because of this statutory nexus between eligibility for Federal

funds and peer 'evaluaticin through accreditation that the Department has

developed criteria and procedures to determine which national, regional,

and specialized accrediting agencies are suitable for inclusion on the

Secretary's list of recognized agencies.

Concern for academic freedom has guided the Department in structuring

its system of recognition of accrediting agenies and its reliance on the

decisions of these accrediting agencies with respect to eligibility of

accredited institutions. The Department exercises its recognition respon

sibility through the establishment of criteria respecting the accreditation

process. Accredittng agencies must be found to be to substantial

compliance with these criteria to order to be listed by the Secretary.

These criteria, however, have been developed only through extensive

cor4ultation with the higher education community and the Natioral

Advisory CoMmittee on Accreditation and Institutional Eligibility.

dit study was conducted by the Educational Testing Service to evaluate,

-the criteria and procedures to recognition to determine their effective-

ness in distinguishing agencies that can be. relied upon to make

judgments concerning educational quality. The study report issued in

May 1980 concluded that the bepartment's procedures reliably differenti-

ate ineffective agencies from effective ones, and our procedures remain

stable from year to year in the interpretation and application of criteria.

It is important to note that the Department does not accredit institu-

thins, but the Department does recognize agencies that are reliableay

authorities. Once recognized by the Department, the accrediting body has

significant influence, since the institutions it approves become eligible

to app.ly for participation in federal assistance programs.

Inhtttutions f4iling to adhere to the standards set by their accrediting

bodies lose eligibility for federal assistance.

Clearly, this process is extremely critical and important to both

postsecondary institutions and the federal government.Th

The concept of accreditation is not new. Accreditation in higher educa-

tion began with the establishment of regional associations of colleges

and secondary schools in the late, 1800's. In the early 1900's prates-

stJn.a., specta.ized accrediting activities in fields such as medicinea

began to be developed. Certain State agencies, such as the New York

Boaru of Regents, ...so conduct accrealting activities.

12

8.

Over the past 30 years, the Commissioner and now Secretary of Education

have been directed to publish a list of nationally recognized accredittng

bodies through some 15 pieces of legislation. These are: the Higher

Education Act, Vocational Education Act, the Act setting up the National

Technical Institute for the Deaf, the Education for the Handicapped Act,

Emergency School Aid Act, Elementary and Secondary Education Act,

College Housing Act, Public Health Service Act, Immigration and

Nationality Act, Tribally Controlled Community Colleges Act, the Act

setting up the educational assistance program for enlisted members of

the armed forces, the Veterans' Readjustment Assistance Act, State

Technical Services Act, Social Security Act, Justice System Improvement

Act, and the Depository Library Program.

There are over 60 separate statutory references to the Secretary 's list

affecting the work of some 10 Federal agencies. For example, over 8,000

of the 9,000 institutions that now hold threshold eligibility status for

one or more Higher Education Act programs have me,: "eratutory

requirements for accreditation by an agency recognized by the. Secretary.

"Threshold" eligibility refers to the first stage of the Department's

two-tier eligibility procedure, wherein institutions or programs are

determined to meet statutory requirements concerning eligibility to apply

for participation in the assistance programs.

Provision is made in the Law for special qualifying steps that may be

taken as alternatives to accreditation. The Three Instituliona 1 Certifica-

t1,:m Process provides eligibility for 50 institutions, for example. State

ipprov ii v an agency recognized by the Secretary is another a Iterna-

lye pubitc postsecondary vocationa. institutions.

rce%-: 4 .-

4 s,13

4

9

Currently, the Secretary, recognizes 77 componerits of 47 organizations as

reliable accrediting bodies. This includes 13 commissions of the six

regional associations and 64 other bodies of national scope that can becharacterized as institutional, specialized, or a combination of the two.One State agency, the New York State Board of Regents, has been

designated by the Secretary as a nationally recognized accrediting body.

Seventy of the recognized accrediting components serve a direct Federal

funding eligibility purpose. AU agencies recognized by the Secretary

serve the program approval function specified in the Veterans'

Readjustment Assistance Act of 1952

It should be emphasized that the commissions of the regional associations

and the national. accrediting agencies and associations have no legal

control over educational institutions or programs. They promulgate

standards of quality or criteria of educational excellence and accredittnsti.utions or programs that, upon evaluation, meet the standards orcriteria. Accreditation, as practiced in the United States, is largely ameans of conducting non-governmental, peer evaluation of educational

institutions or programs. The process is voluntary and the personnel

services provided during accreditation team visits to campuses are usual

unremunerated.

In 1968 the 'Advisory Committee on Accreditation and Institutional Eligi-

bility was chartered by the Department of Health, Education, and.

Welfare to advise the Commissioner on matters relating to both

recognition of accrediting agencies and the Federal el.gibility for

funding process.

10

Under the Education Amendments of 1980, the Advisory Committee received

statutory authorization as the National Advidory Committee on Accredi--.

tation and Institutional Eligibility. The Committee is composed of 15

persons appointed to three-year terms from various segments of the

secondary and postsecondary education communities, the student/youth

population, State departments . of education, professional associations,

and the general public. Supported by the Department's Eligibility and

Agency Evaluation Staff, the Committee advises the Secretary concerning:

the publication of a list of nationally recognized accredit-

in% agencies and associations that the Secretary determines

to be reliable authority concerning the quality of training

offered;

the criteria and procedures for recognizing accrediting

bodies;

the responsibility to designate State agencies as' reliable

authorities concerning the approval of public postsecondary

vocational education and nurse education; and

developing and recommending sAandards and criteria for

specific categories of educational institutions for which

there are no recogntzed accrediting bodies or State

agencies, tn order to establtsh the eligibility of such

institutions on an Interim basis for parttctpatton tn

Federally funded programs.

11

The Secretary 's list of recognized accrediting agencies and associations

is published periodically in the FEDERAL REGISTER. The Secretary

maintains a program of periodic' evaluation of the recognized agencies to

determine if they continue to comply with the Criteria for Recognition.

The recognition process requires the dIsignation of the scope of the

recognized activities of each agency or associati.n . If a recognized body

expands its activities, and desires recognition for the new areas, tt

must petition for such recognitionas part of its regular, periodic

review, or separately.

The Carnegie Report, Control of the Camka, is timely and contains a

number of recommendations that are worthy of our concern over the

issues of educational quality and Federal intrusion into academia.

I have invited the National Ktivisory Committee on Accreditation dnd

Institutional Eligibility through its chairperson, Dr.: Timothy Healy, to

carefully analyze the Carnegie report and make recommendations to me

concerning any necessary changes to the Department 's policies regarding

accreditation and institutional eligibility. When the review has been

accomplished, I will be pitAsed to share our findings with this Sub-;

committee. In addition, I would be pleased to have your comments and

be advised of any concerns you wish to share with me regarding the

important subject of these hearings. In tne meantime, I am pleased to

respond to any questions you may have.

12

Mr. SIMON. Thank you. We appreciate your being here today.Let me just ask one question and I will yield to my colleagues. I

sense from the tone of your comments that you are less concernedabout the status quo than the Carnegie report. Am I incorrectlyreading yok comments?

Secretary BELL. Yes; °I, am less concerned than that report is. Ineed to be careful about that; it is the things you know that arenot so that get you into difficulty. so I do not want to indicate thatwe are not going to pay attention tb what our National AdvisoryCommittee tells us about that.

I feel that if there is too much interference on the part of accred-iting bodies on campuses, that it is largely in thn hands of the ac-crediting bodies. The institutions are collectively responsible forthe a"creditation.

The way that we have tried to works through the accreditingagencies largely passes the baton, so to speak, over to the accredit-ing agencies and since they were created by groups of institutionslike the north-central regicin that you are familiar with, Mr. Chair-man, they have annual meetings and they review issues and atthat time, the whole body of accrediting institutions are there.

Not too long ago, I addressed the Southern Association in Atlan-ta. They were convened in their annual meeting_and it was at thattime that the various commissions of thislargeregional associationwere reviewing their standards.

As sometimes happens, there are member institutions that donot like a decision, or that are critical of a requirement of one typeor another. In my past experience before I came to this job, I wascommissioner_ and chief executive officer of the Utah System ofhigher Edu6ation. Wead in our small State nine institutions.

During budget hearings, the university presidents vkiiild come inand they wou!d say, "We need to have this much money out of thelegislature or we are not going to meet the accreditation stand-ards."

My board of regents often wondered if some of the institutionsdid not ask the accrediting visitors to mark them down in a certainareas so they would have leverage to get what they wanted. So,there are these kinds of critical comments made, I know, fromhaving worked as I have, in this arena. But, by and large, I do notthink that the accrediting agencies set self-serving or unreasonablestandards. They do, however, set some pretty tough and rigorousrequirements.

I am reminded of what is required now to be nationally accred-ited to offer a master of business administration program, the com-petence that has to be represented there. It is a very high standardand not all institutions can make it. And it is often those that feelthat the yardstick is unreasonable in some way or another, thatgenerate some of this criticism, but it does impinge back on thecampus.

I think that it is out of that and the testing that is related to thisthat some of the criticism in the Carnegie report came out.,

Mr. SIMON. Mr. Coleman.Mr. COLEMAN. Thank you, Mr. Chairman.Mr. Secretary, this is kind of a mystical area. I always heard

about being accredited when I was on campus and something teri-

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ble would happen if accreditation did not occur. You shed somelight, but I suppose the real question for me is, who accredits theaccreditation associations and how are there standards in place todetermine who should be an accrediting agency itself?

You kind of cosied right up to the subject and did not discuss itin your remarks. I know you have an advisory committee. Is thatthe important committee, then, that actually performs this func-tion? Where does the buck stop?

Secretary BELL. The final, responsibility is placed on the Secre-tary. The National Advisory Committee was established by legisla-tion and given statutory authority in the 1980 education amend-ments, but it has been in existence since 1968.

This is the body that advises us. I might ask IYr. Elmendorf as heis a former college president, and I am sure he has had to strugglewith these accrediting bodies, to comment more specifically on thequestion, if he will. -

Mr. COLEMAN. What standards are there for this advisory com-mittee to construct or to look at before an accrediting associationis, in fact, listed?

Mr. ELMENDORF. There are some very pecific standards devel-oped In fact, yeti will hear testimony later on today, judging fromwhat I have read of those to follow, that there has been a greatdeal of cooperation by the accrediting associations with COPA, andwith the American Council on Education, in consulting with themin the development of the standards which we then publish in theFederal Register and solicit public comment..Orice developed, they become the medium for any associatior

that.wishes to use the vehicle of accreditation to: (A) get on theSecretary's list; and 113) from that list, then become subsequentlyeligible to receive student financial assistt...ncd.

That is the two-tiered process that the Secretary has explained,and the one that has caused most of the concern relative to eligibil-ity and accreditation in past years.

Secretary Bud.. You might explain the acronym COPA for thecommittee.

Mr. ELMENDORF. Council on Postsecondary Accreditation.Secretary BELL. That is a body out in academe that sort of keeps

an eye on us. They review our standards and advise us, in additionto the advisory committee. They also mirk with the accrediting as-sociations. It is a national organization. I think they serve a veryvaluable function. We have appreciated their input and assistance.

Mr. ELMENDORF. Would, you want some examples of standards?Mr. COLEMAN. Several, not the whole laundry list.Secretary BELL Mr. Rowe has them.Mr. COLEMAN. These are published in the Federal Register, you

say? What might several of the important ones be?Mr. ROWE. Mr. Coleman, these are published as a regulation and

we would refer to them as criteria that the petitioner, which wouldbe the accrediting agency that seeks the recognition from the Sec-retary, would satisfy. In some ways it is an open-book exam in thatthe criteria are publishqd: as we indicated. They involve questionsof the functions that the accrediting agency addresses and satisfies.The organization is described, along with its procedures, its respon-sibility to the public that it serves, and the requirements it has de-

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veloped through its experience with accredited institutions whichhave been approved by it.

The criteria themselves are the product of an evolutionary proc-ess and it is a stated process. When the petition is submitted, it iscarefully analyzed. As a part of the process, our staff would makean observation visit with an accreditation team to an institution inorder to determine if the accrediting association is following thecriteria as stated in their petition. That subsequently becomes partof an analysis report which is shared with the agency, as well aswith the National Advisory Committee, which then subsequentlyholdsand gives an opportunity for witness as to appear inapublic hearing for the petitioner to appear in support of its petitionor anyone from the public, having been given notice of the hearing,may appeair in support or opposition to the petition.

That &Aeration, then, results in a subsequent recommendationto the Secretary and his final decision. This is a process that, asthe Secretary earlier said, is renewed each 4 years. We would bevet.), pleased to submit to you the entire criteria as presently re-quired to be satisfied by the associations.

Mr. COLEMAN. Mr. Chairman, one final question, if I might.First of all, what is the appeal process if the college does not get

accredited, and second, how many colleges are in a position of notbeing accredited on an annual basis?

Mr. ROWE. The appeal process is one of the areas that our crite-ria speaks to and is within the process that each of the recognizedaccrediting agencids, address. They have a stated process whereinthere is an opportunity for appeal by the unsuccessful institution.

The period of time for accredited status granted by an associ-ation would range from several years to a maximum of 10 years.Many of the regional associations grant an institution that is 'vis-ited and is fully accredited by that associat4, accreditation for aperiod of 10 years.

Others might have a lesser period, 7 years or 5 years, and it ispossible, depending on the condition, that the association finds inits review of the institution to have something less than that, andother conditions, may be required depending on the particular asso-ciation finding. Probation or other conditions for a periodic follow-up report may be required if additional problems are discerned.

Mr. SIMON. Mr. Kogovsek.Mr. IWGOVSEK. Thank you, Mr. Chairman.Mr. S6cretary, the Carnegie report suggests that the Council on

Postsecondary Accreditation should be the body' that is solely re-sponsible for accreditation and hearing and deciding on appeal.

Do you feel that this would be a prudent direction for accredita-tion?

Secretary BE.L. I think that this council really renders a fineservice to higher education, but I think that if that became thebody with the sole responsibility, then the Congress, if they tookthat action, would be delegating a responsibility out to a nongov-ernmental entity.

I think you are more in control if you can hold the Secretary re-sponsible, and if you do not like what is going on, haul him up herebefore you for an oversight hearing and say, "What is going on,"and "We do not like it."

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I think that the other procedure, unless there is some way to geta handle on it, would be difficult for you to keep it where youwanted it. With the responsibility that the statute, now gives theSecretary, we could change procedures dramatically. So could anongovernmental agency. L-

I think that with that potential, we have an adequate procedureto determine whether or not students at a given institution shouldbe eligible to participate in the student aid program, that is the bigpart of it, but,there are other reeuirements, too.

Mr. KOGOVSEK. In relation to that answer, Mr. Secretary, I thinkyou and I are both bothered by that word "control," and, we do notlike to use it. I know you do not like to use it. The Reagan admillis-tration,repeatedly.states as one of its goals, the lessening of Feder-

'al intrusion into State and local governments and the private..sector.

Do you feel that the role of the Federal Government in recogniz-ing accrediting agencies contributes to this intrusion, getting backto my original question, limiting it to one

Secretary BELL. It certainly does. This puts you on the horns ofthe dilemma. I am reminded of my earlier time in Washingtonwhen we were having a large number of institutions participate instudent. aid, and keep in mind that private proprietary institutions.can participate.

I remember an episode involving a group of barber colleges. Weamended the statute and said that "In order to participate, youhad to be accredited." The proprietor of these barber collages im-mediately organized his Barber College Accrediting Associationand declared his institutions accredited.

I guess the quality of the work and the preparation of these bar-bers left much to be desired from the complaints we were gettingabout it. Well, when that maneuver happened, that is when Con-gress became concerned. That is when the Federal Government gotinto it. Congress said, "Not only do you have to be accredited, butthe accrediting body has to be approved by the Federal Govern-ment."

Now, that is where the mischief comes. That shoves us right overinto that. I have spent nearly all of my adult life in education, andin the process, I have many times been outraged with the Feds.That is why I often discuss Federal control up here.

But I do not know a way around this one if we are going to avoidthe maneuver that I just described to you. But it bothers me thatwe even have that potential for Federal control. The more that wecan preserve local autonomy and enhance academic; freedom, thebetter education is going to be in this country.

Mr. KOGOVSEK. Thank you, Mr. Secretary.Thank you, Mr. Chairman.Mr. SIMON. Mr. Packard.Mr. PACKARD. Thank you, Mr. Chal(man. It is a pleasure to have

the Secretary back again.Most of my experience, Mr. Secretary, has been in elementary

and secondary education. My only exposure, as some of the othersmentioned, to higher education is my own experience in the col-leges and universities.

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Would you, for my benefit atleast, briefly outline the steps andthe procedures that an institution would normally have to ,gothrough in order to be accredited? Would you also review for mehow those accrediting conditions are established?

Are there different accreditation procedures for a medical schoolas compared to a law school, or a school of music, or even a beautycollege? Are they accredited through the same system that any 4-year university or junior college would be accredited?

Secretary BELL. A very insightful question, Mr. Packard, and Iwill try to handle that as best I can.

If a new institution were established, and they wented their stu-dents to be able to receive student aid, such as to participate in theguaranteed loan program, college work-study and grant programs,and so on, the hiltitution would have to be approved.

If they establish themselves with good standards, those that aregenerally accepted in the profession, they could at the outset, getthree accredited institutions to assist them by indicating that theywould accept their credits from students who transfer from thereover to their institutions. 7"'

Now, there is more to that requirement than what I am saying,and I will leave it there. An institution just beginning would startthere. Then they would apply for accreditation with an appropriat-.',accrediting association.

Out in. California, Mr. Packard, it would be the Western Associ-ation. They would have to fill out an application for accreditation.They would have to meet some initial ;standards that the accredit-ing association has .established,oThe community of the institutionsout there have banded together and organized their accrediting as-sociation and have worked together to set their standards.

They have an organizai.'on, they have a board of directors, andeach year they meet at an annual meeting and review the stand-ards and elect their officers and so on. This hypothetical new institution would, if they met the requirements, receive some kind'oftemporary status if not full accreditation unless that was earned.

Dick, would it be candidacy or what would the officio! term bethere?

Mr. RowE. It could be candidacy for accreditation. Yes, sir.Secretary BELL. Then following that, Mr. Packard, as they grew

along and establish themselves, they could become fully accredited,but it is not a procedure that happens quickly. As a member, then,of the accrediting association, they would have a voice, as amember would have, in what the standards would be.

Now, if they were not approved, or if they could not get even thisthree-letter approval, then they would not be able to participate inany of the Federal funding. In many instances, there would beother problems that they would run into. Graduates' credits wouldnot be accepted and they probably would not exist as an institutionfor very long.

Mr. PACKARD. Other than participating in Federal funding andperhaps the transfer of credits, what are the advantages of beingaccredited or the disadvantages of not being accredited?

Are private institutions also in this accreditation process, and dothey come under the same requirements?

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Secretary BELL. ,Yes, the private institutions also have to beaccredited if they want to have this participation. The other advan-tage is that they are then able to state in their publications and intheir bulletins and so on that they are a fully accredited institutionand that means a great deal to students and parents and to coun-selors 'in the high schools. As you read the publications of variousinstitutions, they list their accrediting status in that regard.

Now, if you were a ,Harvard or cri Yale or a very longstanding dis-;Anguished iestitution, maybe your reputation would carry youwithout that, but even those institutions maintain their accredita-tion standing

Mr. PACKARD. Does the Accreditation filter down to all institu-tions of higher learning, even in very specific fields of study?

Secretary BELL.`Yes, we also have specialized accrediting agen-

cies; many of thenY, we could say most of them, are in the health-eelated fields. We had a situation in Memphis not too long agowhere a Congressman called our attention to the problem downthere and we referred the problem to the accrediting body that hadaccredited this institution.

So the private proprietary -type schools also have their accredit-ing bodies. Business schools, the traditionally private ones that tra-ditionally trained secretaries and accountants and so on, have theirrecognized organization, and they have their accrediting associ-ation.

Mr. PACKARD. But who sets the standards of accreditation forthese very specific colleges and universities like a dental school ora medical school? Are they set by people outside of that professionor does the profession itself get involved in the standards of ac-creditation of those kinds of schools?

Secretary BELL. It varies with each entity. I think particularly inlaw ant medicine. The American Bar Association and AmericanMedical Association have a great deal to say. Not only the institu-tions, but the organization itself, has a great deal to say about thestandards of accreditation. But they must satisfy the criteria thatlargely have been established by our advisory body, if they are tobe recognized by the Secretary.

We listen carefully to COPA, which is the umbrella organizationfor higher education accreditation; however, it does not include allof the private proprietary institutions.

Mr. PACKARD. Thank you, Mr. Secretary.Thank you, Mr. Chairman.Mr. SIMON. Thank you.Mr. Owens.Mr. OWENS. No questions, Mr. Chairman.Mr. SimoN. Mr. Gunderson.

.Mr. GuNmEitsoN. Thank you, Mr. Chairman, and Mr. Secretary,for appearing.

I guess as 1 listen to you, I read your testimony, I seem to followup on Mr. Kogovsek's remarks, that if it is the policy of this admin-istration to reduce the role of government in education, this seemsto be one of the outstanding candidates, compared to many of theother things that we are considering.

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If you were to propose the absolute minimum amount of govern-ment intervention from the Federal level in accreditation, holywould you change present law?

Secretary BELL. If I wanted to have the minimum--Mr. GUNDERSON. Minimum necessary in your opinioh.Secretary BEI.L. Well, L. would possibly add to the statute in

giving more direction to the Secretary. If I wanted to'be certain asheads of the Department or successor entity would come and go, Iwould give rtIgher statutory direction that would limit what youcould require and what you could not require for approval to be onthe accrediting list.

Now, the ideal, of course, would be to repeal the statute totally.But the ideal, as often happens, is one of the tragedies in our lifeand bumps head on with the practical, and the practical is that wehave so many institutions out there, excluding little proprietaryschools here and there, and Congress permits them all to partici-pate if they can meet the accreditation and eligibility require-ments..

If you did not have that "if" there, there could be all kinds offraud and abuse and ripoff. So, as long as we are going to be spend-ing $7 billion in higher education on the Federal level, we need tohave some kind of quality assurance.

I would not want to give the impression that the system that wehave now does not considerably minimize the amount of interfer-ence, because of the fact that we use the means that we use, of rec-ognizing what already exists out there in academe, and those ac-crediting entities are not under the control of the Federal Govern-ment. They are under the control of the institutions collectively.

Now, you could start to coerce if you had a Secretary of Educa-tion that decided that he would change that procedure, and he hasbroad discretion now to do that if he wants to.

Mr. GUNDERSON. You mentioned earlier in your remarks in talk-ing about the Harvards of the world and some of the other schoolsand I recall when I made a choice as to where I was going toattend college that I never once checked on accreditation. It did, notmatter a bit to me, and I do not think it mattered to my parents ormy guidance counselor. I think reputation matters a great deal.

Would ypu agree that reputation far exceeds even the concernsof accreditation in the selection of a school?

.Secretary BELL. 1 think it depends upon how large and howwidely known the institution you attend. If you attended a nonac-credited institution that was a very small liberal arts college thatwas not known outside of the State borders, in fact, was not knowninside the State if it was a very large State, you would run intodifficulty as you wanted to move from there.

Suppose you had a baccalaureate degree from this hypotheticalinstitution and you wanted to do graduate work at a university.You would probably run into difficulty in having your credits ap-proved and received and your being admitted to graduate school. Ithink that is where the accreditation would be significant.

I might also point out that most of our high schools in theUnited States are also accredited. It is not as critical there as it ison the college level, but even on the high school level, registrars

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and admissions officers are looking at what high stools areaccredited as they review standards.

Mr. GUNDERSON. Has accreditation done anything to improve theability of the student to transfer credits from one school to an-other? It seems to me that that problem still exists, even though allschools are accredited. Ought that not be one of the major goals inthis area?

Secretary BELL. The institution still can reserve the right andthe faculty, the academic cotnIiunity, may.admit w'lom they willunder requirements that they have, and so it is not a guaranteethat if you are a graduate of an accredited institution that you willbe automatically admitted or that certain credits will not be chal-lenged.

But it does tend, to make the credits "legal tender," if I may usethat term, more sol.han would be so without it.

Mr. GUNDERSON. Do you feel that more should be done in thisarea of transferring credits through accreditation, or do you notfeel that is the role, or one of the roles, that accreditation canplay? 1

Secretary BELL. Well, I think that it is a role that accreditatioA,can play, but I would defend the right of each institution to settheir kiwn standards and to refuse to accept certain credits to meettheir requirements if they choose to do that.

Most institutions that I know much about, if they have a ques-tion, they would have some provisional requirements, sometimesrequiring an examination or other means, to 'determine whether ornot to accept the credits.

One university that I Vow quite well, if you transferred therefrom one of these private proprietary business colleges, a 2-yearsecretarial, science, bookkeeping and accounting type school, theymay admit.you to accounting, and to a third- or fourth-level courseif you had the first two, and then, depending upon how.well you doin the more advanced accounting course, they would make the deci-sion, at least one university that I know about delays its decision ofwhether or not to accept your credit from this business school.

That is a business school that is fully accredited by this nationalorganization, incidentally. That is the way it works in.a universityin my home State.

Mr. GUNDERSON. One final question. In terms of the role of ac-creditation, particularly from the perspective of the department inguaranteeing that there be minimumNstandards of achievementand competency required, do you feel 0164 there is a greater needfor the Department's involvement,jn accreditation of specialized ac-crediting bodies, as opposed to the regioial accrediting associ-ations?

Secretary BELL. I do not believe so. I do not -know if my col-leagues would like to comment on that or add more or take somefrom that, but I do not see a greater need. .

I hesitate to come before this committee and sqy everything isjust great and perfect with how we are handling this responsibility,which this committee and the Senate committee put in tbe statute,I can say, however, that I wish that everything in the Departmentof Education was functioning as well as this is.

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Mr. GUNDERSON. I would make one statement. Concerning theSecretary's statement that the. responsibility for coordinating spe-cialized versus regional accreditation really belongs with the aca-demic community itself. I 'believe that with the proliferation of theSpecialized groups, aigr,..:..t.deal more could be done through region-al coordination so that jou do not have overlap or unnecessary du-plicative functions.

I do not believe that is our role, but I do believe there is a roleand I do believe it is a problem.

Thank you.Secretary BELL. ,I would like to note one thing, if I may, Mr.

Chairman, that I failed .to respond to. Dr. Elmendorf passed me anote on this, Mr' Gunderson. I think it is important to distinguish

° between credits being accepted and being counted toward a degreein an area of specialty.

If a student attended a vocational technical institute, a postsec-ondary one, and had a course in welding where he was developinghis skill capacities, those credits could he accepted, and they wouldshow on the transcript. But probably the major university in theState, unless there was some special exception, would not countthat particular kind of a course toward a.degree..

People say, well, they would not accept my credits, when reallywhat they would not do was count these credits toward a specificdegree because they did not fit the need that the faculty in thatdepartment required.

Mr. SIMON. Mr. Secretary, we thank you, Dr. Elmendorf, Mr.Rowe, for being here. I will submit questions to you for the record.

[Information referred to f011ows:]

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wANSWERS TO QUESTIONS FOR SECRETARY BELL FROM PAUL SIMON

Do you have any particular opinion Ion the link between State licensure apdspecialized acrrediting bodies? Are there any actions the Federal governmentcould take to prohibit that lipkage?

"I'''

A, The link between State licensure and specialized accrediting bodies is not a

subject that is presently reviewed in,the recognition process conducted by theDepartment oc Education. State licensure of an institution is an agencyrequirement that must be satisfied before an Institution may be accredited by arecognized accrediting agency. The State licensure of an individual's voca-tional or professional competence is often associated with the applicant'scompletion of an accredited program of studies. This link between the State andthe applicant regarding licensing requirements is appropriately a State concern.

Presently, we know of no reason to support any Federal initiative that wouldprohibit a link between State licensure and specialized accrediting bodies.

Q. Ynu stated in your testimony that you4thought the present system of accredita-tion was working well. However. it appears that as a general trend tHe numberof accrediting agencies is increasing. -Do you think this expansion is necessaryand will continue? How does increasing .the number of agencies affect thequality of the accreditation system?' . .

YPS, the present vstem of voluntary accreditation is working w611. The Depart-ment presently recognizes 77 agencies. This includes 13 recognized regionalaccrediting commissions. rather than,including in our count only the 6 sponsor-ing associations, and the 11 review committees that cooperatewith the Committeeen Allied Health Education and Accreditation (CAHEA), the single unit within the

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American Medical Association that q the final decOsion-making authority for alarge variety of Allied health education pro'grams. Counting only the mainorganizations, as was done in 1952. the current list of recognized accreditingbodies stands at 47 to growth of 19 agencies in the last 30 years).

Th15 modest expansion is partially the result of the dramatic recent growth ofpostsecondary educatioti durio the past few dem This growth of recognized

Nsagencies now appea's to have stabilized,, and we be ve only a modest number ofadditinnal agencies will seek recognition. Indeed, m ch of the growth reflectsthe need for specialized accreditation services..particularly in the health andtechnical areas where the advance in scientific knowledge has created a demandfOr sheCialitd aervice. in order to assure that technical and specialized educa-tion is competently delivered.

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There is no *vilence that the iacrease in the number of agencies has adversely.affe:ted tee

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Quality of the accreditation system.

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Q. What percentage of agencies which apply for accreditation status receiveit?

A. Approximately 641,' of the agencies which applied for initial recognitionby the Secretary were successful. A number of agencies which withdrawtheir petitions or are denied initial recognition chose to improve theirpetitions, correct deficiencies, and establish compliance with recognitioncriteria prior to resubmitting new petitions for recognition. Twenty ofthe 55 agencies that sought recognition as nationally recognized accreditingbodies since 1968, when our records were first established, were deniedinitial recognition and did not reapply. In addition, ten agencfes developeddraft petitions but did not request formal action when they discovered thatthe criteria were more demanding than the agency could satisfy.

Q. Now many agencies lose their right to accredit institutions as a result ofthe Department's reviews?

A. No agency loses its right to accredit institutions as the result of theDepartment's action. However, the Department has withdrawn the Secretary'srecognition from three accrediting agencies. Since institutions must berecognized by the Secretary in order to receive federal funds, such loss ofrecognition has a major impact. There are agencies that operate an accredita-tion service that have never sought the Secretary's recognition. An agencymust be established and operate successfully for at least a two-year periodbefore it may submit a petition to the Secretary for his review and determinationof.the agency's iTliabllity. The recognition by the Department of an agencyas a reliable authority as to the quality of education or training offer'd byeducational institutions and programs authorizes an institution, accredited bysuch a recognized agency, the )pportunity to obtain eligibility to participatein various Federal progr ms. Three national agencies and one State agencyhave been removed from tne Secretary's list subsequent to receiving recognition.

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Secretary BELL. Thank you.Mr. SIMoN. Because we have a full committee meeting at 41:30, I

am going to take the liberty, if there is no objection from the othermembers Of the committee, to ask the next three witnesses to` be ona panel and we will hear all three and then toss questions at thethree of them.

Dr. Ernest Boyer, the president of the Carnegie Foundation forthe Advancement of Teaching, and former Commissioner of Educa-tion; Dr. Jack Peltason, president of the American Council on Edu-cation, and I might mention both of these gentlemen are formerresidents of the State of Illinois. I know that the members of thesubcommittee are very interested in hearing that, and Dr. RichardMillard, the Executive Director of the Council on PostsecondaryAccreditation.

We want to thank Commissioner Boyer for giving us, all themembers of the subcommittee, copies of the "The Control of theCampus," the book that your foundation produced.

Dr. Boyer, we will hear from you first.

STATEMENT OF ERNEST 1.. BOYER, PRESIDENT, CARNEGIEFOUNDATION FOR THE ADVANCEMENT OF TEACHING

Mr. BOYER. Mr. Chairman, and members of the committee, I ampleased to be here to explore with you an issue which I consider tobe an important one to the future of higher education. I commendyour committee for the oversight inquiry that you are making.

I know the time is short and I will therefore highlight issues rel-evant to your inquirOnto this matter of accreditation and the Fed-eral role in it.

I respect very much Secretary Bell for his work, and I respect hisopinions expressed, particularly on. accreditation. I do, however,feel an obligation to highlight, based on our own committee report,and if I might do so, based on my own personal experience, a fewaspects of the issue that I think are troublesome.

It is my opinion that the current arrangement of Federal over-sight of /Accreditation is, in fact, flawed at four very fundamentalpoints. First of all, it is my opinion that the Department of Educa-tion has clearly moved beyond the intention of the law, and I in noway speak to the current administration, I speak of a history thatdates perhaps 10 or 15 years, so I share part of their responsibilityof which I speak. This is in no way to be viewed as a comment onthe current administration.

Over the years, what started as a simple strategy to sort out thegood apples from the bad apples, that is, is this institution mini-mally to be trusted in order to get Federal aid slowly, but surely,moved into an elaborate device to accreditation an end in itself.

Quite simply, the Department has become the accreditor of theaccreditors, and as I see it, unwittingly perhaps, the Commissioner,now Secretary, has become the national commissar for accredita-tion.

I see nothing in the intent of the law,kliat\ created this procedureto have a device by which an agency %vigil* to be certified as anaccrediting body should have Federal authority. Rather, the devicewas how can the Federal Government figure out a means by which

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we eliminate those who might be untrustworthy in handling Feder-al money. Those are two very separate processes.

So, in my own view, this process has sloOly gone far beyond whatwas originally intended. Let me give you a'n example.

A university might be regionally accredited. That says in effect,you, are legitimate, you are no fly-by-nighter, we can trust you toget Federal money. II: ut that is not enough. An accrediting agencyin speech or journalism or psychology comes to the Secretary andsays, accredit us. Then these bodies are established, even thoughthey are subgnits within an already legitimate institution.

I see no reason why the Fedeiml Government is engaged in ac-crediting bodies that are not necessarily related to cross the thresh-old of legitimacy for Federal support.

Let me give you another example. The health science, freestand-ing science institution, not one part of the university, they receiveappropriate accreditation through their medical association.

Nonetheless, the Secretary, or Commissioner of Education alsowould accredit the health science, the clinical lab association, orthe nurse anesthetist association, or the physical therapy associ-ation, even though they are subunits within an already accreditedunit.

Second, I must say that I think the current arrangement in-volves the Government in a function that it is not well equipped toperform and, in fact, that does not work very well in the end.

When I was Commissioner, I studied with care these criteria thatwere asked for this morning, but not clearly defined. I can only tellyou that when you get your list of criteria the Department uses,you will find them very vague and you=will also find them priisx-ily dealing with process and not with substance.

You will see questions about who is on your accrediting board, doyou allow for due process, but I can only assure you that after thatelaborate procedure is met, and all of the criteria established herein Washington have been met, in the end, the Commissioner orSecretary has very little, if any, assurance that there will be aprocess to assure the institution is safe and legitimate as a place toreceive Federal money. It just does not work.

For example, we have had default rates that have plagued thisGovernment since student loans began. When I was Commissioner,the NDSL rate, as I recall, the default rate was 18 percent. Theother loan program, guaranteed loan, was hovering around 12 or 13percent.

The irony is all of those institutions were accredited. We did aninstitution-by-institution analysis to discover that some accreditedcolleges had a default rate of 5 percent, some had a default rate of85 percent, they were all regionally accredited, and some of themhad specialized accreditation from 8 or 10 organizations.

Now, we have this elaborate procedure not to accredit, but ratherto guarantee that the Federal moneys are going to accreditable in-stitutions, only to discover that when you pull back the veneer ofthat, the range of efficiency went from high efficiency to absolutescandal.

So we have, it seems to me, machinery in which the Government ,..-----has gone beyond the intent of the law. The criteria are vague,.andin the end, it does not work.

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There are two other concerns which trouble me very much frompersonal experience you might say, Mr. Chairthan. I believe thecurrent arrangement is used by special interest groups to resolvedisputes.

Now here I draw the distinction that one of the colleagues madebetween regional and specialized. I think that is a very importantline of inquiry to pursue.

When I was Commissioner, there was a dispute among the podia-trists as to which of the accrediting organizations emerging repre-sented the true philosophy of podiatry. I found myself in the ratherunconfortable position of having to listen to long testimony, andindeed was taken into court to justify my decision of having ap-proved Podiatry Accrediting Association A, as opposed to PodiatryAccrediting Association B, based upon some subleties of how onetreats sore feet. I must tell you, I was not, in my judgment, the bestjudge in the world to draw that line.

On the other hand, I simply say that is the end result of thisbusiness of naming a Coinmissioner or Secretary to become the au-thority in determining the policies within the interior of these spe-cialized bodies and having to say, you are the bodyithat truly rep-resents this specialized association. They in turn then go to the col-leges and establish their Good Housekeeping Seal of Approval.

I do genuinely believe that the accrediting process at the Federallevel is occasionally used by special interest groups to air their owndisputes.

The final point, and I think this is what brings us to this tabletoday, at least it' certainly is the point that our own Carnegiereport took special cognizance of, is the current accreditation ar-rangement, especially of the specialized bodies, which is used togain prestige by those bodies and then that prestige is in turn usedto bring leverage against colleges and universities.

Let me spell this out the way I think it goes. A special interestgroup wants to gain added leverage and prestige nationally. Whatis the simplest way to do it? Under the current law, it is to come toWashington and get the Commissioner, the Secretary of Education,to put you on "his approved list." Now once you meet those crite-ria, then you can immediately print in your brochure, "Recognizedby the Secretary of Education of the U.S. Government."

With that kind of leverage, you can then go to colleges and say,"We are on the Secretary s approved list. Therefore, we feel weshould come to your college to have oversight of that particularpart of your program,"

The leverage then moves right down on the campus and I think,if I might say so, Mr. Chairman, Secretary Bell's view of the pres-sure that brings to institutions was, frankly, quite more sanguinethan our own.

When I was chancellor of the State University of New York, Iremember vividly we were having an internal discussion with oneof our distinguished specialty colleges that I thought was world-ranked about whether they were going to get two associate deansappointed. This was budget-crunch time. I did not think theyneeded the two deans, but the dean of the college thought they did.

Well, lo and behold, accreditation time came and I was waitedupon, If that is the right word, by the accrediting committee from

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that specialized body and they advised me that if we did not ap-prove those two deanships, associate deanships, that the accredita-tion of that institution was in jeopardy.

I was frankly, nonplussed. I said, "I have been told now for yearsby the dean that this is the world-rankjng institution in this partic-ular speciality." These two administrative appointments now plum-meted-the school to the point where you do not even recognize it asworth of accreditation.

It was clearly a ploy, and ,I mention it here, not to air my owndirty laundry, but to say that there are examples that could be re-peated frequently that indicate the specialized accrediting, in someinstances, is used to advance certain special ends of the special in-terest groups.

Now, I do not blame the Secretary of Education for these abuses,but I do find it curious to suggest that the Department can standaside and say, well, that is the institution at work, when in fact, allof the authority for that activity is drawn precisely from the Feder-al Government.

I do not think that the Government can e detached from a proc-ess that eventually works its way down to the local campus. Now,whether through criteria one can avoid this or not, I am not sure,human beings being what they are.

We do suggest in our report, however, and I will close my re-marks with this. We think a lot might be gained in the spirit ofderegulation and very little, if anything, lost. If, in fact, we lookmore to the association that has been established as the umbrellaorganization, holding it accountable to be sure in some ways thatthe law might establish.

But the irony is, and here I can only speak as a former bureau-crat, the current arrangement makes the Secretary fully responsi-ble, while in the end, there is very little control he has over theoutcome, and he still then sees the fraud, abuse and the other fall-out that occurs.

I do believe that there may be a way, in answer to the questionof Mr. Packard, what is the way we might resolve this dilemma?

I think it would be possible to take one further step toward self-regulation to establish criteria that might . be understood by theCouncil on Postsecondary Education and then let the profession, infact, be held more accountable than we do today, simply believingthe current arrangement does not work.

I might say, Mr. Chairman, that in the end, based on my experi-ence, accreditation notwithstanding, the Administrator of this De-partment still has to decide if an institution is so abusive thatfunds must be withheld.

In the end, the decisions, the agonizing decisions I had to make,were not on the question, well, is this a good accreditation commit-tee or a bad one? Frankly, that was paperwork.

In the end, the real question was, do we have on the margins of .this great operation some institutions, even those accredited, thatare not doing their job very well and what do we have to do aboutit?

So the administrative buck simply falls back on you in the end.With all of the best intentions, I think the accreditaition process is

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an area where Government could, in fact, take one more step backand in the process affirm the importance of self-regulation.

In the end, I think that would perhaps be a clear line to repre-sent the reality that we have.

Thank you very much., [The prepared statement of Ernest L. Boyer follows:]

PREPARED STATEMENT OF ERNEST L. BOYER, PRESIDENT, THE CARNEGIE FOUNDATIONFOR THE ADVANCEMENT OF TEACHING

Mr. Chairman and Members of the Subcommittee;

I am Ernest Boyer, president of the Carnegie Foundation for

the Advancement of Teaching. I wish to thank the committee for

inviting me to meet with you today.

I am pleased to discuss briefly a recent report on the

governance of higher education prepared by The Carnegie

Foundation. This report entitled, The Control of the Campus,

asks: How can colleges and universities maintain their

independence while being answerable to the various constituencies

they serve?

We conclude that, in the strictest sense, there is no such

thing as autonomy in higher education. And we suggest that it is

irresponsible for educators to take public money or private funds

and then complain when asked to be accountable for such support.

The key issue then is not whether colleges and universities

can be detached from the world of which they are inevitably a

part. Rather, the issue is where the line should be drawn

between the campus and the state and, most especially, how can we

separate out trivial interferencerom essential confrontation.

We conclude that in the end, the academy must be given full

authority over what we call in our report the essential core:

the selection of faculty,,the conduct of courses and research,

the processes of instruction, the establishment of academic

standards, and the assessment of performance.

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That recitation may ..sound unusually familiar, but these

functions constitute the core of academic life, and it is here--

at these points--that the independence of the camp3s must be

uncompromisingly defended by faculty, the president, and by the

governing board, which stands as a shield between the campus and

the constituencies beyond.

Having defined the basic ground rules of academic

governance--we then move in our report, to the issue of whether

the integrity of higher educatibn has, in fact, been violated by

the state, or federal government, or the courts.

putting it simply, has government been as bad< we have all

believed?

Here, I must warn that our cofizlusion will be a keen

disappointment to those who have a "conspiratorial" view o

academic history. We found -- during our two-year study--few

examples where public officials have tried overtly to control the

essential functions of teaching and research.

And, in fact we consider it a remarkable achievement that so

much public money has been channeled to the nation's public and

private campuses with so little interference.

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I.

Accreditation: The Federal Connection

Mr. Chairman, there are however, several issues raised in

our report that I should like to focus on today. The first, is

accreditation.

In 1944, Congress passed the Servicemen's Readjustment Act,

.the so-called G.I. Bill. Under this law, Veterans were entitled°

to education benefits if they attended institutions "approved" by

.state education agencies--but no one was quite sure what it meant

to be approved.

The Veterans' Administration had no authority to tell states

how to carry out this responsibility. As a result, fly by night

programs were acccrectited. Shocking stories of scandal and abuse

began to circulate in Congress.

In 1952, the rules were tightened. congress directed the

United States Commissioner of Education to help state agencies

determine eligibility by "publishing a list of nationally

recognized accrediting. agencie8 and associations which, he

determines to be reliable authorities as to the quality of

training offered by an educational institution." The

commissioner's first published list of twenty-eight approved

accrediting associations was dr:;)n,largely from the National

Commission on Accrediting, the umbrella association of

accrediting bodies.

3422-141 0 84

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During the past thirty years, the Commissioner's authority

to approve accrediting associations has been reaffir.ned in at

least twenty-five separate statutues. And as accreditation

received official blessing, more and more associations sought

federal approval. An office called the Division of Eligibility

and Agency Evaluation in the United States Office of Education

develops() detailed criteria to decide which accrediting agencies

the goveinment should approve.

.Dy 1982, sixty-four associations--both regional and

Ilrofessional--were on the Commissioner's (now Secretary's)

list. Self-regulation in American higher education was formerly

backed by the power of the state. The bureaucracy was kept busy

evaluating the evaluators. And access to billions of federal

dollars is now limited to institutions accredited by agencies on

the Secretary's approved list.

Frankly, Mr. Chairman, we conclude that this process has

gotten out of hand. The Commissioner, now Secretary of

Education, has become, by default, the nation's accreditation

czar. Special interest groups push to get on the Secretary's

approved list--even though such listing has at times little or

nothing to do with determining whether an institution should be

eligible to receive federal support. It is inappropriate we feel

for the federal government to involve itself in accreditation as

an end in itself, a function that takes the Department of

Education far beyond the intention of the law, and imposes on it

an evaldation activity it is ill equipped to carry out.

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We, therefore, have two very simple recommendations.

o First, we recommend that in determining the

eligibility of colleges to participate in federal

. pStgrams, the Secretary of Education should use

regional accreditation as the basis for approval.

o we also recommend that--the Council of Post condary

AccreditatiOn--not the federal government be he

agency,to prepare the approved list of regional

ass4.niations. Cuch an assessment would return us to

the procedure that was used by the Commissioner when

the first list of approved accrediting associations

was established.

I.might say parenthetically, Mr. Chairman, that if the

Council on postsecondary Accreditation is given s-ch authority,

it must demonstrate its capacity effectively to do the job, and I

further believe, that the nation's college and university

presidents should become still more actively involved in the work

of the Council on Postsecondary Accreditation.

Our concern about government's connection to accreditation

is related to cs:fern that specialized accreditation bodies

approved by the Department of Education may themselves threaten-

the integrity of the campus. In fifty years,.the list

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of approved accrediting bodies has grown from a.ssmall core to

sixty-four associations, ranging from the Council,for Non-

Collegiate Continuing Education to the American Association of

Marriage and Family Therapy, to the AmericanBoard of Funeral

Service Education. Today, on many campuses a,dpzea or more

visiting teams impose requirements that compromise the authority

of the trustees and undermine the overall priorities of the

institution.

The issue here is not whether professional programs should

meet high academiC standard. It is, rather, how detailed fhose

standards should be; how they should be enforced: and, most

importantly, whether pecialized programs to improve their own

demands, are to fit within the larger purposes of the campus.

Looking ahead, tensions among departments and disciplinesi,

may increase as budgets tighten. In such a climate,

professionals on campus may be even more tempted to abuse

accreditation, using the process not to protect the public and

promote excellence but to gain leverage in the competition for

dollars.

More ominous is the fact that at least twenty-one

associations have now been linked to occupational licensure by

the state. Through such arrangements, specialized accrediting

bodies--using the authority of their feleral recognition--wield

enormous power over higher education. They control entry into

the professions, and often give states strong_influence over

academic matters.

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To fit specialized accreditation more effectively into the

overall governance of higher education the following

srecommendations are proposed that depend not so much on the

federal connection but om the academy itself:

o We recommend that standards for specialized

accreditation focus on outcomes, and campus

evaluations should be conducted with full respect for

the overall mission of the institution.

o We also recommend that colleges and universities not

invite to campus any specialized accrediting agency

whose criteria for membership are so intrusive or

detailed as to weaken an institution's own authority

over teaching and research.

6 we further recommend that spedialized accreditation

teams coordinate their visits with regional 1

associations, and, whenever possible, such

collaboration should involve sharing information and

preparing combined surilmary reports.

o Finally,.we recommend that state governments

reexamine the link between occupational licensing and

specialized accreditation. In sou cases, alternate

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routes, to licensure, such as formal examinationsor

practical experience should be provided. In other

cases, the link between licensing and accreditation,

should be broken altogether.

Government and The Academy: New Structures

r

At the outset, Mr. Chairman, I suggested that government has

not seriously involved the integrity of higher education. This

does not mean, however, that he relationship has been problem

free.

I recall during my own tenure as Commissioner, the furor

over default on student loans and theG-5ubsequent Proposal by

government to separate eligibil.ty from accreditation which would

have put the Office of Education directly in the accreditation

businons. I also recall the confusion when the Office of

Education proposed regulations related to the campus refund

policy for students who dropped out. I further recall the debate

on how to regulate research on recombinant DNA should the

government give researchers a free hand in the leformation field

and did it have a right--indeed a moral obligation - -to impose

constraints?

qb.

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And what about protecting human subjects. Again, does

,government havean obligation to see to 4t that federal funded

research does not harm participating individuals?

Mr. Chairman, we suggest in our report that even in the best

of worldefundamental' questions such as these will be with us

always. The governance of higher education is a dynamic not a

static issue and we conclude that new government-university

'forums should be created to improve communication, resolve

differences, and to move forward policyrecommenaations as new

important issues are confronted.

e

o Specifically, we recommend that the National Academy

of Sciences, establish a government-higher education

research forum to exchange ideas, search for

agreement on research policy and resolve disputes

over the administration of existing progtams. Such a

forum should be' organized in consultation with

Appropriate federal agencies\!nd professional bodies.

o We also recommend that the American Council on

Education, working with the Department of Education,

should also establish a government-higher eaucation

student assistance forum to exchange ideas, search

for agreement on policy, and resolve disputes over

the administration of-student aid programs. The

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Council should also enlarge the work of its Office of

Self-Regulatory Initiatives.

o Further, we propose that the policy guidelines

developed by the American Council on Education's

self-regulation project and by the new forums

recommended in our report be considered for adoption

at every instituion of higher learning to which they

apply.

o And finally, we urge that guidelines should be used

by accrediting teams to assist in the evaluation of

individual campuses.

If federal involvement in higher education has been

relatively benign, how is it that there has been, until recently

et least, so much complaining about government intrusion? The

answer lies, at least in part, in what we call "the cumulative

impact." One regulation may not be restrictive, but many

regulations quite literally smother an institution.

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III.

2.DeerIdelt_21nstitutioilc:ASecial Issue

Mr. Chairman, there is one other matter in our report that

seems relevant to this hearing.

In assessing the impact of federal student aid on the

nation's campuses, we identify one overarching issue,

We note that, today, hundreds of campuses now receive much

of their annual revenue from the federal program of student

grants or loans.

In 1978, federal student aid funds (excluding guaranteed

loans) were equal to about 50 percent of the tuition revenues at

public comprehensive colleges and to vie than 45 percent of

tuition income at public two-year colleges.

At private liberal arts colleges, federal student aid,

(again exclusive of guaranteed loans) was equivalent to more than

25 percent of the tuition revenues. In aggregate, this federal

support represents about 13 percent of the total income of

private liberal arts colleges-a level of dependence that would

have startled private college presidents not many Years ago.

The governance indications of this dependency c.,.:

profound. A network of federallyrelated institutions has been

created.

/inost ali colleges and universities are now to some

extent d endent on Wasington for survival. And, in the long

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run, this may prove to be the most important governance issue to

be faced.

We do not suggest, of course, that federal student aid

programs should be restricted. Equal opportunity must continue

as the bedrock educational policy of this nation.

But this new interdependent relationship does place a

special obligation on government to see to it that the level of

support is not abruptly changed. It also means that student aid

should not be used to achieve other ends that would place

inappropriate burdens on the campus or impose--even indirectly- -

political or legal or academic obligations that would restrict

the institution and threaten the essential core.

Simply stated, in order to keep the governance lines very

clear, student eligibility for aid should be based solely on

student needs.

The founders of this nation were wise to restrict the role

of the federal government in the control of American higher

education. The nation's leaders have also been.enlightened in

recognizing that there are certain educational objectives that

can best be served by federal support. Reconciling this

important principle--federal support without federal control--hi.Q

created a need for both vigilence and trust and the development

of appropriate governance machinery to handle conflicts as they

arise. Our recommendations have been designed to meet this

challenge.

Mr. Chairman, it is in my view, an act of statesmanship that

this committee of the House has convened a hearing on the

relationship between government and higher education. I commend

you and the Committee for your leadership and, once again,

thank you for the opportunity to meet with you today.

4.3

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Mr. SIMON. Thank you very much, Dr. Boyer, great o have youback again.

Mr. BOYER. Thank you.Mr. SIMON. Another regular visitor here, Dr. Jack Peltason.

STATEMENT OF JACK PELTASON:PRESIDENT, AMERICANCOUNCIL ON EDUCATION

Mr. PELTASON. Thank you, Congressman Simon, and colleagues.Because of the time and the fact that you have my written state-ment, let me just make a few brief comments endorsing in greatpart and with much enthusiasm the remarks made by my col-league, Mr. Boyer, elaborate on them briefly, and then we willhave time for questions.

I am pleased that you are getting into the subject of accredita-tion. It is one that ordinarily leads to glazed eyes, a subject that isof great importance, but infinite complexity.

I would just build on Ernie's comments and set aside what I wasgoing to previously say because he said so much that I would liketo say. The Council of Education and the other educational associ-ations feel very strongly that the responsibility for accreditationdoes belong to the higher education community.

. We at the same time recognize that there is a Federal responsi-bility to determine who is eligible for Federal funds. The kinds ofconcerns of these two things get improperly intermixed and arequite real.

Both under Mr. Boyer and under 'Secretary Bell, the FederalGovernment has, I think, made considerable steps away fromtrying to get involved too much in details of accreditation, but thatdanger still exists.

If the community is going to ask the Nation to rely upon its ownself-regulation, then it is incumbent upon ta to make that self-reg-ulation work more effectively. I think we have made some consider-able progress _in this area in the last several years.

The natioliiil educational associations have recently worked withour colleagues in COPA to restructure it in order that the heads ofthe institutions will have a greater voice inside the machinery ofCOPA and can make it work better.

We,have also smarted to develop our own guidelines of self-regula-tion in addition to accreditation, publishing these and buildingthem into the accreditation process.

As Mr. Boyer pointed out, what we are trying to do is build insti-tutional accreditation as the centerpiece. Our concerns are primar-ily with the problems within the community of the proliferationand duplication by specialized accreditation.

We recognize that there is 13 legitimate role for some specializedaccreditation. Along with the Carnegie Commission, I ask if we canalso give you a report on a National Commission on Higher Educa-tion Issues, recently issued under the leadership of Robben Flem-ing, former president of the University of Michigan, I call your at-tention to the recommendation of the Commission on pages 6 and 7where they endorse the statements that you will find very similarto those found in the Carnegie Foundation report.

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40

That leads me to my final comment that just as sometimes theFederal Government is used ,improperly by specialized groups, aneven greater threat, in my judgment is the improper mixing up oflicensing requirements at the State level and specialized accredita-tion where a group will go and get the State legislature to adoptthe requirement that you cannot practice the profession, or eventake the examination, unless you have met the prior approval ofthat specialized accrediting agency.

We think that the protection for the public can be obtainedthrough COPA approval, COPA being the association which ismade up, and Mr. Millard will elaborate on this, I am sure, of rep-resentatives of the accrediting association, of the specialized accred-iting associations, and of the institutions.

We feel that within that machinery, we can develop the stand-ards and we can avoid the use of licensing, not to protect the con-sumer, but in essence, to build the privileges of a profession. In theeducational scene, I can elaborate from my own experience onwhat Ernie talked about where at budget time, specialized accredit-ing teams lean upon you and tell you that you have a fine pro-gram, but they need more space, need to double their salaries, theyneed more secretaries. Otherwise, you might lose the accreditation.That is not usually accreditation to maintain its quality, but tobuild the profession.

What we are asking is that both the Federal and the State Gov-ernments not allow themselves to be used in that kind of a strug-gle. We think that through the strengthening of COPA that is thesingle most important thing that car be done to meet the multipleobjectives.

[The prepared statement, with pamphlets, of J. W. Peltasonfollow:]

41

PREPARED STATEMENT OF J. W. PELTASON, PRESIDENT, AMERICAN COUNCIL ONEDUCATION 1

Mr. Chairman and Members of the Subcommittee:

I am Jack Peltason, President of the American Council on Education. I

am pleasedto have this opportunity to discuss'the subject of accreditation on

behalf of the presidents and chancellors of colleges and universities, as

Chairman of the Assembly of National Postsecondary Educational Organizations

(ANPEU), which represents their views in the deliberations of the Council on

Postsecondary Accreditation.

These hearings present an opportunity to empasize the importance of

nongovernmental accreditation. I can assure the Subcommittee that the higher

education community is continually engaged in the process of self-evaluation

which is necessary to maintain accreditation as a viable means of quality

assurance.

All of the higher education associations, representing the entire

spectrum of postsecondary institutions, are deeply committed to self -regu-

lation. First and foremost, it is a professional responsibility of higher

education to regulate itself. For this reason ACE, acting on behalf of the

communi y, established its Office on Self-Regulation Initiatives to develop

community guidelines in problem areas, and to advise institutional adminis-

trators on sound practices. In the last year we have issued guidelines on

standards of academic progress, confidentiality of personnel files, and

academic integrity and athletic eligibility.

Accreditation, of course, is the centerpiece of self-regulation. We

have consistently urged the Congress to retain the nongovernmental, voluntary

accreditation status granted by institutional accrediting agencies as the

principal means of establishing eligibility for federal funds. The only

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42

alternative is governmental regulation, which would put federal officials in

the impossible and unacceptable position of making judgments on the educational

standards of colleges and universities throughout the nation.

While we strongly support nongovernmental accreditation, it is important

that we be candid with the Congress'and the general public about the difficul-

ties inherent in the accreditation process and its general weaknesses. We are

pleased that this is a principal focus of the Carnegie Foundation's Report on

the Governance of Higher Education. As the Report points out, accreditation is

not as healthy as it should be, and we generally endorse its recommendations

for improvement.

The problems of accreditation should be discussed under two separate

headings: institutional accreditation (the regional associations and a few

.national agencies which accredit the total institution); and specialized

accreditation (conducted by the ever growing number' of agencies dealing with a

specific curriculum).

Institutional Accreditation

Although the Report addresses only the regional accreditation agencies,

it is important that these recommendations be implemented also by national

accrediting groups, such as the Association of Independent Colleges and Schools

and the National Association of Trade and Technical Schools, which are equally

important as the regional associations in terms of the federal reliance on

nongovernmental accreditation.

Perhaps the most important Carnegie recommendation is that more of he

leadership from the nation's best colleges and universities must become

involved in institutional accreditation as policy makers and as visiting teams

members. Such leadership will be essential to implement the improvements

recommended in tne Carnegie Report. This is a point ACE has been stressing for

several years.

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The Association of Governing Boards of Universities and Colleges (AGB),\

which serves as a member of ANPEO, has also stressed the importance of trustee

,participation in the process of accreditation as a means of meeting their

critical responsibility for overseeing institutional autonomy and integrity. A

series of recommendations for trustee participation in institutional and

specialized accreditation recently adopted by the AGB Board of Directors states

that the "neglect of this opportunity by trustees may itself be a serious

threat to the future of American higher education and two of its unique and

essential features: self-regulation and lay trusteeship." Everyone within and

outside of the field of higher education should appreciate the fact that those

who005present the public interest by virtue of their service on the boards of

the nation's colleges and universities are increasingly active in helping to

address the issues of concern to all of us.

ACE and the other ANPEO associations will be working through the COPA

Assembly of National Postsecondary Educational Organizations to consider and

implement the Carnegie recommendations.

Specialized Accreditation

The Carnegie Report notes that in some instances specialized accredita-

tion actually threatens the integrity of the campus. I agree, and here again

ACE endorses the Carnegie recommendation while noting that the battle aver the

requirements of specialized accreditation has been waged for fifty years. It

is no less intense today than it was when it was first begun. Although I think

it will become less heated, I see no end to the controversy for, as the Report

notes, colleges and universities cannot carry out.their work in isolation.

Professional associations have a legitimate interest in the educational

programs that prepare practitioners to enter a given field. They also have

important contributions to make in&improving educational programs and in

2

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identifying programs of superior quality. In many cases, when kept in proper

perspective, specialize° accreditation serves an important educational and

social function. However, some professional groups tend to use specialized

accreditation as a lever to gain professional advantages which often create

imbalances in the distribution of institutional resources.

The Carnegie Report recommends that state leyislatures reexamine the

\.. link between occupational licensing and specialized accreditation. ACE

strongly endorses this recommendation because the tie gives specialized

agencies unwarranted leverage on institutions. It is critically important that

the Congress not add to this leverage by using specialized accreditatiOn as a

means of establishing eligibility for federal funds.

In our judgment, federal policy and procedures have already gone a stepI

too far in bolstering the role of specialized accreaiting agencies by including

them on the list of "Accrediting Agencies and Associations Approved by the

Department of Education," when few of these agencies presently have any role

in establishing eligibility for federal funds. ACE has recommended in the

past, and continues to recommend, that a role in establishing eligibility for

federal funds be the first criterion for inclusion on the Department's list.

Agencies that have no Congressionally-delegated role in eligibility

should oe deleted from the list: to include them hampers the community's

self - regulation efforts by eroding the effectiveness of COPA sanctions in

assuring responsible behavior on the part of accrediting associations. we

believe that national recognition of specialized accrediting agencies is the

proper function of the Council on Postsecondary Accreditation. Institutions

should look to COPA to assure that requirements and practices of accrediting

agencies are educationally and socially sound.

Summa

In summary, I would stress again that nongovernmental, voluntary

institutional accreditation, even with its imperfections, is the best mechanism

Congress can ihoose to establish eligibility for federal funds. Higher

education and the accreditation community are aware of the problems, and we

have begun to deal with them. The recommendations of the Carnegie Report are

on target, and point the directions we must yo for further improvement of the

system.

4'9

I n 1981, a special subcommittee of thePublic Policy Committee of the AGB

Board of Directors was appointed todetermine: 1) how the Association caneducate its member tru.itees on thepurposes of accreditation; and 2) howthe Association and members of govern-ing boards can participate constructive-ly in the activities and procedures ofaccreditation with the objective of main-taining educational quality and properinstitutional autonomy.

The members of the Subcommittee

22-141

45

on the Role of Trustees in Institutionaland Specialized Accreditation were:

Clark Kerr(Chairperson)Manager Emeritus,Swarthmore College

Merrimon CuninggimTrustee, Vanderbilt UniversityTrustee, Duke University

Ann Ida Gannon, BVMTrustee, St. Louis UniversityTrustee, St. Michael's CollegeTrustee, Ursuline CollegeDavid M. Lascell, Esq.Trustee and Chairman, Wells College

Mary Louise PetersenFormer Member,Iowa State Board of Regents

Samuel J. SilbermanTrustee, Fairleigh Dickinson UniversityJ.L. Zwingk(Consultant)Former President of AGB

Nancy R. Axelrod(Staff)Vice President for Programs

and Public Policy, AGB

The subcommittee met six times overa period of 16 months. A survey wasconducted to explore the range of trusteepractices in institutional and specializedaccreditation, and several leaders in thefield of accreditation were consulted.This report was prepared by the sub-committee and adopted by the AGBBoard of Directors on November 5, 1982.Although the Association of GoverningBoards will continue to address theissues in this report, these recommen-dations complete the work of the sub-committee.

Tice members of the subcommitteeexpress their gratitude for the assistanceof Nancy R. Axelrod and I.L. Zwingleand for their diligence in assuming themajor resronsibility for writing this re-port.

5o

46

nhke many countries that dependIL, on a centralized ministry for qualitycontrol Of their educational enterprise,.the United States uses a nongovern-mental, self-regulatory system of as-sessing the institutions that make up itspluralistic system of postsecondaryeducation. The ultimate responsibilityfor the integrity and autonomy of col-leges niversities rests with the laymembers if governing boards. Adminis-trators and faculty members contribute tothis effort by enforcing standards andreviewing educational effectiveness.The academic community also participatesin the process of accreditation throughvoluntary associations of institutions andprograms that seek to assess and enhancethe quality of an institution or programand assure the public that their membersare operating in the public interest;

The intent of this report is to showhow the participation of trustees in theprocesses of voluntary' accreditationcan give them an immediate and effective' grasp of their critical task of oveseeing institutional autonomy andintegrity. Further, it will be seen thatneglect of this opportunity by trustee'smay itself be a serious threat to thefuture ot American higher educationand two of its unique and essential fea-tures: self-regulation and lay trustee-ship. A fresh look at the purpose's andproc edures of accreditation can takecolleges and universities a long waytoward regaining control of their owndestinies and finding a renewed senseof common purpose among institutionsot all types. Failure among governinghoards to take seriously the import of astrong and ettec five system ot nongov-ernmental at c regulation could weakenthe American educational enterprise byencouraging governmental bodies toassume the responsibility for controland assessment.

In the field ot voluntary at recitation.there are two major types of ac tivity:institutional a« redoing: and 2, spec ial-'red or programmatic accrediting. 1 hefirst of these is carried on by the sixregional associations ot colleges and

51

schools and the four national institu-tional accrediting bodies. The secondtype is carried on by some 38 nationalorganizations concerned with rofes-sional study (law, medicine, ofd thelike) or with occupational or Iliscipli-nary programs, institutions, or unitswithin institutions. Both groups are self-governing membership organizations.An umbrella organization, The Councilon Postsecondary Accreditation (COPA),certifies the legitimacy of accreditingorganizations and coordinates andmaintains communication amongthese groups.

The original interest in institutionalaccrediting arose over transfer ofcredits and thus focused on academicstandards (requirements) among insti-tutions. In the less than a century of itshistory, institutional accrediting hasevolved through several stages, fromthe first qUantitative measures of facultytraining, faculty-student ratios, vol-udies in the library, to more broad-scaleconcerns about clarity of purpose, con-sistency of performance, and assess-ment of outcomesall these pointedtoward questions of institutionalviability, integrity, and similar concerns.

It was once true that after an institu-tion received accreditation there waslittle effort to review its performance;but that time is long past. Typical prac-tice today is for institutions not only tobe reviewed regularly but for interimreports to be made. Moreover, there isan increasing practice to require specialreports within a range of six to 24months, depending on the nature of theproblem. Despite these changes inpractice, it is still falsely assumed bymany that, once accredited, memberinstitutions have few or no further de-mands to meet.

The function of the review in the pro-cess is not only continuance of ac-creditation but institutional enhance-ment. Thus it is an exercise in 1) self-examination and 2) peer review, throughwhich process even the most distin-guished institution may discover for itselfcertain areas of needed improvement

47

and, with the help of well-selected visi-rors, may gain new in.iight on some ofthe inevitable problems of maintaininggood practice.

It is important for governing boardsto take special interest in this 'self-

1 assessment. Institutions today confronta set of forces that threaten the self-determination of instiiut!nns and tendto weaken-voluntary accreditation. Theseforces are to be found partly in thenature of the current national situationand partly in the relations with govern-mental agencies, both state and federal,as they deal with colleges and universi-ties. In these and other instances, thereare growing criticisms of voluntary ac-creditation and expressions of doubtthat the' system will any longer sufficefor the future.

As for the national situation, notmuch need be repeated here; The floodtide of students has begun to recede;the national economy has weakened.Competition among institutions hasincrea3ad. Public criticism of educationhas mounted. New practices ant pro-grams among the colleges have raisedquestions about the quality of certainofferings. Dubious advertising andother promotional schemes have led tosuspicions of fraud. The swing towardenrollment in public institutions ismarked, and the pl'ght of the privatesector in education a continuing topicof discussion.

Cdncurrently institutions must dealwith renewed activity on the part ofstate higher education departments andother agencies of state government, notto mention the continued role of thefederal government in all fields of edu-cation. Many feel that the period of en-rollment decline and program consoli-dation we enter will encourage stategovernment to play a more aggressiverole in program review and in shapingcritical policy decisions in postsecond-ary education. In the midst of this ex-pansion of governmental role the criti-cisms of voluntary accreditation havemounted, most especially from gov-ernmental sources. At times it seems

that validity of peer review is acceptableonly when negative decisions arereached. Confidentiality is viewed asconnivance. And somehow the protec-tion of the public interest'is seen as agovernmental function, beyond thereach of the private sector or a system ofpeer review otherwise accepted in suchfields as medicine and law.

In the literature of accreditation severalthoughtful analyses have been publish-ed, setting forth clearly the importantdifferences in the functions of stategovernment, federal government, andthe voluntary associations. It would bewell for members of governing boardsto acquaint themselves with at leastsome of these publications.' But themessage for trustees to hear is not a callto battle against state and federal gov-ernment. It is to emphasize the need forthem to grasp the significance of volun-tary accreditation and to seek means bywhich their own share of responsibilityhere can better be discharged.

As for the criticisms of institutionalaccrediting, limitations of space willpermit only a summary. One favoritecomplaint is that the membership ofregional associations is an "old boys'club," wherein old routines prevail andnothing new ever blossoms; that theprocedures are slow and cumbersome,obstructing prompt action when need-ed; and that reviews are scheduled tooseldom for any sustained benefit.Another criticism concerns the pro-liferation of specialized accreditationthat tends to emphasize particular pro-grams at the possible expense of theinstitution as a wholeand in fact mayimpinge on institutional independence.It might be useful to deal with thesecriticisms as part of this report, but suf-fice it to suggest that trustees shouldstudy and discuss these matters.

Ise.erdl helpful pubha ahl,m dee Wed tn Inr &Pd.( p It heel puhI. shed by the t nunt It un Pusts4K imclan Act ,V(1,1,11,1/n I I/PA.

cnf,nes nl IN% 1.1cdiei a,e dij),V,Ip nee ()P4 sum,'tat t nu. Dupe ml (let le NdslunKittn U ( Mitt liehneet ri onthe act reelthetg pm( es, (do al,. he ohtd-ted lion, ihe regtosidlinshlut.onal at nrd,fng hexlee, and the 4,e,41.ted dteeenhttngtxxlee,huted in the( (WA brow hu/e

The point is not to explain or defendthe procedures of the voluntary accrediting groups, but io emphasize thatthe process of accreditation is importantto every college and university, that itbears heavily upon the issues of institutional vitality, integrity, and self-determination.' Any presswe towardintrusion by state or federal agenciesconstitutes ultimately a threat to thefuture of non-governmental accredita;tion and the role of trusteeship. Thebest safeguard against that untowarddevelopment is in the readiness of goy-erning boards to utilize the proceduresof accreditation as a means of accomp-lishing a major part of the central bus!ness of thee boards themselves forundertaking: 1) institutional planning;and 2) periodic evaluation.

Because accreditation is concerned- largely with academic matters, some

consider the lay trustee to be unquali-fied to participate significantly and thathis/her attempts to do so,may be diver-sionary, obstructive, meddlesome, evendangerous. Moreover, the process ofaccreditation and review is slow andtimeconsuining, demanding morethan is reasonable to expect from thetypical member of the governing board.Further, within large state-wide systemsor at least multiple institutions undertheir supervision, the boards couldnever be expected to scrutinize indi-vidual institutions very closely.

Leaving aside for the moment thequestions of time, workload, and spe-cific approac he for appropriate trusteeinvolvement. let us consider a matter ofprinciple: At the core of accreditationare two concerns that dire( tly overlapimportant trustee duties cited earlier.-institutional planning and periodicevaluation. True. these are not tunctions of the individual hoard membersbut central to the corporate responst-billh, ot hoards f or trustees to giveursory attention to stall reports or oral

comments on sue h matters is to neglec Ithe very essence ot the enterprise Inthe ac c redoing pro( ess, governingboards could disc ver immediate as-

5:

48.

sistance`'and direct access to this vitallyimportant task.

An important decision then is this:How will the board and administrationshare the activity involved in selfstudy,the maintenance of high standards,the reach for improvement, and thesafeguarding of the integrity of self-re-gulation,. _all'of which underlie theaccreditation process? The followingrecommendations for board participa-tion in institutional and specializedaccreditation are offered to guide thosetrustees and chief executives at Institu-tions which do not have a level of boardinvolvement sufficient to render theboard accountable in this self-regula-tory activity. A variety of effective prac-tices have been identified in the courseof the AGB subcommittee's investigation.

These recommendations should bereviewedlnd adapted to fit the needs,size, and complexity of the institution;the style and organization of its board;and the requirements of the individualaccrediting organization(s) to which theinstitution belongs. Trustees andregents must look to their presidentsand chancellors to help them partici-pate constructively in accreditation asstewards and policy makers rather thanpart-time administrators, meddlers oracademic specialists.

Recommendations for board participationin institutional accreditation

RECOMMENDATION I Members of theboard should; 1) be informed of thehistory, current practice, and strengthsand weaknesses of their institutional ac-crediting associations; and 2) partsci-pate, along with their administratorsand faculty members, in their activities.

Current accreditation practices havebeen criticized by educators. public of-ficials, and even those who administerthe work of the accrediting bodies. likethe colleges and universities they ac-credit, the regional associations under-go self-study and concern themselveswith self-improvement. As members ofthese associations, trustees. administra-

for andand faculty members should helpevalbate and strengthen accreditingcriteria and standards.

One of the most effective forms, ofparticipation, ether than carrying outthe necessary procedures as institu-tional candidates for accreditation orreaccreditation, is service on accredit-ing teams. Trustees should encouragetheir faculty and administrators to serveon the visiting teams for other institu-tions, and they should be willing to contribute time themselves as public members of teams or the commissions thatgovern the regionals if they are quali-fied to do so.

To prepare foesuch additional serviceto higher eduotion, trustees should beaware of the ongoing activities of theirinstitution's regional association. Thiscan be done by reading the associations'newsletters, reviewing policy docu-ments, attending membership meetir.gs,or asking the president to keep the boardapprised of these matters.

Some of the regional associationshave developed video tapes, work-shops, and other training devices tohelp educate trustees and others abouttheir purposes and practices. At thevery least, a discussion of accreditationshould be placed on the board agendawell in advance of the self study processto make sure the board is aware of: a)the objectives, scope, and cost of thisactivity; and b) its role in the process.

RECOMMENDATION II The boardshould actively participate in the institu-tional self-study.

The selfstudy is at the heart. of theaccreditation process, and it is an exet-cise that should be welcomed by theboard as complementary to its responsi-bilities for: approving institutionalmission and goals; ensuring soundinstitutional planning and financialmanagement; and evaluating institu-tional performance. It should be viewedas an integral part of institutional plan-ning rather than simply as a means ofcomplying with accrediting require-ments. In addition to assessing its own

49

effectiveness as a part of the self-studyof the institution's governance, boardmembers should be willing to roll uptheir sleeves in working with otheraspects of the self-study as suggested bythe chief executive. The final self-studyreport which is sent tb the accreditationteam may be WO voluminous to send toeach board member. The responsibilityof reviewing the report might be .dele-gated to a board committee or a sum-mary of the findings could be sharedwith each trustee.

Trustees have often served as mem-bers of the institutional steering com-mittee typically organized to coordinatethe self-study. Board members may alsobe asked to complete questionnairesadministered by the steering commit-tee, and board officers are sometimesinvited to review drafts of the results ofthe self-study. Depending on the organ-ization of the board, it may be useful toassign a standing (e.g., academic affairs)or specially appointed board committeeto work with the selfstudy. Trusteescan also be helpful in identifying otherswho can contribute to this stage of theaccreditation cycle such as members ofvisiting committees and advisory councils.

The self-study process is too often asometime thing, whereas it should becontinuous. If indeed the self-studydoes become continuous, the periodicreview is made all the more valuableand much less demanding. Yet evenamong the most prestigious of institu-tions, it occasionally has been foundthat serious neglect of these functionscomes to light when the external reviewtakes place.

RECOMMENDATION III - The boardshould be informed of the objectivesand activities of the visiting team.

If one accepts the proposition thatthe present procedures for accredita-tion can and should be strengthenedbut that the overall responsibility forthis activity should continue to be arm,governmental, the accreditation teamwhich visits the campus should not 1wtreated as an unwelcome group of ex

54

ternal examiners. The board can helpthe president set the stage to receivethe team as a group of peers whosecandor and objectivity will help theinstitution pursue its own goals of self-improvement, self-renewal and rededi-cation to quality programs and services.

If misgivings about the team arebased on ignorance, orientation pro-grams should be planned for campusconstituencies to explore the function,nature and value of accreditation. Ifthey are based on dissatisfaction withthe accreditation criteria of the agencyor the methods employed by previousteams, the board should be aware ofthese concerns and be prepared to con-sider recommendations for improvingthe situation.

RECOMMENDATION iV - The board orits representatives should meet with thevisiting team.

Accrediting teams which completetheir campus visits without any directcommunication with board membersare likely to leave the institution withserious questions about board involve-ment in the governance process Theway in which the trustees interact withthe members of the visiting team shouldbe a function of the requirements of theaccrediting associations (some routine-ly schedule meetings with board mem-bers) and/or the wishes and inde-pendent initiative of the board and chiefexecutive. In some instances, hoard of-ficers or the members of the executivecommittee are interviewed. In othercases, all of the members of the hoardare ent ouraged to meet with the visitingteam to disc uss board priorities, long -

range planning and other matters.

RECOMMINDAT 10N The boardshould review the final report of the aucrediting team, evaluate its findings,and help implement those recommenda-tions it approves.

I he nnal report of the accreditingteam may call Ior significant institutionalhanger and financial expenditures_

50

Therefore, the board must understandthe rationale for the recommendationsbefore it can approve the changes ininstitutional organization or practicesdeemed necessary to meet the associa-tion's standards as expressed by thevisiting team. Once the board has con-sidered the final report and discussed itwith the chief executive, it should re-view carefully its role in the imple-mentation of the recommendations,encourage and authorize the adminis-tration to implement approved recom-mendations, and ask the president toprovide it with periodic progress re-ports to monitor these activities.

The internal self-study and the re-ports of visiting teams provide readymeans for governing board review andreactionnot of course in full detail butin such manner as to provide responsi-ble insight, foresight, and oversight.The planning and review of institutionalmatters revealed by such reports shouldbe foremost in the concerns of faculty,administration and board membersanatural medium of mutual interests. Toengage periodically in this exercisedoes not commit the board member tospending an inordinate amount of timeor to a substitution of lay judgment forthat of the expert. It does commit thetrustee to pay close attention to therecommendations of accrediting bodiesand the reactions of faculty and adminis-tration to these recommendations.

Recommendations for board participationin specialized accreditation

As a review of specific programs with-in an institution, specialized accredita-tion requires perhaps a different kind oftrustee participation from that recom-mended for institutional accreditation.Nevertheless. the relationship of spec-ialized accreditation to trustee concernssuch as academic standards and thesubstantial Imam gal and personr ' costsInvolved in some of the specialized re-views warrants a role for trustees in thisseitregulatory activity as well. In theminds of many . this is an area where theboard must delegate the lion's share

On Multicampus Systems

Boards responsible for multi-campus systems may shrink fromany suggestion of involvement inaccreditation activities because ofthe apparent magnitude of thetask. Certainly there is a specialproblem here. But such boardsshould ask themselves and theircentral administrators to thinkabout possible approaches to thistask without inviting completeoverload.

Regular reports from the systemstaff can help central boards to bereasonably informed about majorfindings of accrediting teams.Many systems have advisorycommittees of some sort, affiliatedwith the units within the system.These groups could well be includedin some pan of the larger issues ofassessment, Where such a sugges-tion will not fit, there is the possi-bility of special committees co-optedby the board to examine some ele-ments in accreditation reports andto form some judgment about mat-ters worthy of attention by thegovereTing board.

While recognizing the variationsin muhicampus structure and boardorganization, the board must be in-volved in accreditation in ways sug-gested by these recommendations.

of the institutional responsibility to itsadministration. But it must also expe..tthe president or chancellor to keep itwell informed of the policy implicationsof specialized activities.

RECOMMENDATION I - Trustees shouldbe familiar with: a) the purpose andgeneral requirements of the agenciesthat conduct specialized accreditationreviews at their institution(s); (b) theschedule and general activities for eachreview; and (c) the estimated direct andoverhead costs of such reviews.

Keeping board members informed as

51

to which agencies visit the campus, howoften they come, what criteria they im-pose, and what this means to the institu-tion is a much greater task at larger,more complex institutions that mayparticipate in several specialized re-views. It need got be burdensome if thechief executive presents periodic pro-gress reports to the board in summaryfashion. If a board committee structureexists, it may be appropriate for theacademic affairs committee to reviewthese reports on behalf of the board andfor the financial or executive committeeto review the financial commitment ofthe institution to the specialized ac-creditation activities. At those institu-tions where the cost of specialized re-views will represent a significant por-tion of the budget, the board may heasked to approve whether specializedagencies will be invited to consider.ac-creditation of new programs, or to re-view the cost/benefit ratio of existingarrangements with specialized agencies.

RECOMMENDATION II - Boards shouldask their chief executives to share withthem highlights of the findings of thespecialized visiting team.

Typically, individual trustees do notreview the reports made by specializedagencies, i ut the board's responsibilityfor approving the educational programshould encompass periodic assIss-ntents of the results of the specializedreviews. In some cases, board memberswho are professionals in the field of re-view may be asked to participate in theself-study or the visit of the team. Themethod will depend on the size of theinstitution and the organization of theboard, but all approaches shov'd pro-vide the board with an overview of thefindings of the specialized visiting team,the requirements of the agencies theyworesent. and the consequences forthe institution.

RECOMMENDATION III - Board mem-bers should participate, along with theiradministrators and faculty members and

5

representatives of the specialized agen-cies, in the periodic review of special-ized accreditation practices.

Governing boards are a good posi-tion to appraise the work of specializedagencies because trustees are expectedto rm., ke decisions on the basis of thewelfa. a of the entire institution ratherthan on the needs of a specific disci-pline. Specialized accrediting agenciescan influence teaching toad requirement:,budgeting standards, kinds of advanceddegrees required of the faculty, thelength of the program, and other aca-demic policies. These requirementsshould be measured against overall insti-tutional mission and priorities estab-lished by the board and administrationrather than used as the sole basis forshafting the academic program. Boardmembers can help distinguish betweenthose requirements of the agency thatrepresent encroachment in institutionalgovernance from those that encourageneeded program improvement.

Trustees can encourage specializedteams to relate their individual programobjectives to overall institutional objec-tives. Trustees can also encourageinteragency cooperation when it ispossible to arrange for complementarytime schedules among specializedagencies and to coordinate specializedand institutional accreditation cycles.Board members can make a contribu-tion as members of specialized visitingteams if they have expertise in theparticular held of inquiry.

52

This booklet is the fourteenth in a series, ACBPocket Publications, designed to give both newand experienced trustees concise, summary in-formation on subjects and issues of high inter-est to governing boards. Titles in the series are:

No. 1Trustee Responsibilitesby lohn W. Nason

No. 2Trustee Orientationand Development Programsby Richard 1. Ingram

No. 3The Fund-Raising Roleby Michael Radock

No. 4Trustees and Preventive Lawby Kent Weeks

No. 5Academic Collective Bargainingby Kenneth P. Mortimer

No. 6Resource Management Responsibilitiesby Charles A. Nelson

No. 7The Tenure Issueby Richard P. Chait andAndrew T. Ford

No. 8The Board Chairpersonand the Presidentby lohn W. Pocock

No. 9A Guide for New Trusteesby Nancy R. Axelrod

No. 10Building a More Effective Boardby Robert L. Gale

No. 11Institutional Planningby Rhoda M. Dorsey

No. 12Affirmative Actionby Betty

No. 13Managing Your Endowmentby I. Peter Williamson

No. 14The Board's Rolein Accreditationby the AGO Subcommittee on theRole of Trustees in Institutional andSpecialized Accreditation

ToStrengthen

Quality in HigherEducation

SUMMARYRECOMMENDATIONS

OF THENATIONAL COMMISSION

ON HIGHEREDUCATION

ISSUES

58

NATIONAL. COMMISSION ON HIGHER EDUCATION ISSUES

Members

Ismael AlmodivarPresidentlniversity of Puerto Rico

Richard C. AtkinsonChancellor'ni% ersit of California. an Utego

Robert H. AtwellVice PresidentAmerican Council on Education

William 0. BakerFormer Chairman of the BoardBell Laboratories

Thomas A. BartlettChancellor'inversit of Alabama SyqC111

Robert D. Bentonstate Superintendent ofPublic InstructionState of Iowa

Donald M. BlinkenChairman, finard of Trustee'sstate I 'mversity of Nc York

Derek C. Bok, ex nifiLChair. American Council onEducationPresidentI Lnard I imersit%

David M. Clarke, S.J.PresidentRegis college I colorado

Robert L. ClodiusPresidentNanonal Association of stale

imersities and I.andtirantolleges

Eugene Cota- Robicsprm,N. it (.1 'liege'ni% et slit- nt e'alitorma. sant.' Cruz

Mark H. CurtisPresidentAssoc latHili ut American colleges

i homas R. DonahueseL retar% -treasurerNH LiuMencvc DunhamPI es tdent

larke college c li i\%.i I

59

Edward B. FiskeEducation EditorXtql )brk Times

Robben W. Fleming, ChairFormer PresidentCorporation for Public Broadcastingand University of Michigan

Leila FraserVice President MarketingThe Marine Corporation

E.K. FretwellJr,Past Chair. American Council onEducationChancellorUniversity of North Carolinaat Charlotte

Thomas W. Fryer, Jr.ChancellorFoothillDe Alva Community CollegeDistrict

Robert L. GalePresidentAssociation of Governing I3oardsof 'iliversIt les and Colleges

David P. GardnerPresidentU11111: rSity Of Ptah

Sheldon HackneyPresident'mversity ut PennsvIvama

Fred K. lioehlerjr.Executive Directorkorge Meant' Center for Labortidic%, Inc

David L. JohnstonPrincipalMcGill rim ersitBryce JordanFAct UtiVe \IL C Chancellor for

ademic Affairs'imersity cif Texas h stem

Francis). KerinsPresidentCarroll College t Ntontana

William A. KinnisonPr;sident

menberg I ins.ersiR

Douglas M. KnightPresident(uest.ir Gm-poi-anon

Marjorie Fine KnowlesProfessorSchool of LawUniversity of Alabama

George M. LowPresidentRensselaer Polytechnic Institute

Charles "A" Lyons, Jr.ChancellorFayetteville State University

Robert H. McCabePresidentMimniDade Community College

Robert S. McNamaraFormer PresidentWorld Flank

Catherine T. McNamee, C.SJ.PresidentCollege of St. Catherine

Barry A. MunitaPresidentChief Operating OfficerFederated Development Company.

Samuel L. MyersExecutive DirectorNational Association forEqual Opportunity in I figherEducation

Barbara W. NewellChancellorState University System Of Florida

Frank NewmanPresidentI ifiversity of Rhode Island

Allan W. OstarPresidentAmerican Association of StateColleges and Universities

Dale ParnellPresidentAmeriCall ANsoClation iif COM nt unityand Jan tor Colleges

Benjamin F. PaytonPresidentTuskegee Institute

J. W. PeltasonPresidentAmerican Council on Education

John A. Peoples,Jr.PresidentJackson state I "niversity

55

Roy P. PetersonDeputy Executive Directorof Academic AffairsKentucky Council on Higher Education

John D. PhillipsPresidentNational Association of IndependentColleges and Universities

Gary H. QuehlPresidentThe Council of Independent CollegesRobert D. RayGovernor of the State of Iowa

James M. RosserPresidentCalifornia State University,Los Angeles

Gloria Randle ScottVice PresidentClark College (Georgia )

Virginia B. SmithPresidentVassar College

Thomas M. StaufferDirectorNational Commission on HigherEducation IssuesChancellorUniversity of I patClear Lake City

Hov'ard R. SwearerPresidentBrown University

Stephen Joel DuchtenbergPresident'niversity of Hartford

Phyllis A. WallaceProfessor of ManagementAlfred P Sloan School of ManagementMassachusetts Instituteof 11:chnology

George B. WeathersbyCommissioner for Higher Educationstate of Indiana

Arnold R. WeberPresidentUniversit of ColoradoDavid A. WilsonExecutive Assistant to thePresidentI n iversity of California SystemwideAdministration

60Nr-q-

b4:31h

56

ForewordThe National Commission on Higher Education Issues, composedof knowledgeable men and women inside and outside the post-secondary community., was established to help the nation's col-leges and universities address some of their pressing concerns.The Commission, which existed for a year and held four meetings,was organized through the cooperation of ten presidential-levelhigher education associations and was financed by the John D. andCitherine T. MacArthur Foundation.

From the Outset, the Commissioners decided not to be astudy group, not to have background papers prepared, and not topublish a voluminous report for wide circulation. The goal was,rather, to take advantage of the differing perspectives and cumula-tive experience of the CA numissioners in order to make a fewconcrete, brief, and practical recommendations to those whomake policy and implement decit ions in higher education.

For higher learning, the n?t)st precious asset is publicconfidence. Despite constrained resources, higher education has,on the whole, managed to maintain the quality of its programs. Butthere are signs that quality standards are being jeopardized. Crit-icism is growing that many entering students are deficient in theacademic skills'itecessary to successful pursuit of higher educa-tit m. along with the subsequent suggestion that degrees no longercertify that those who earn them are men and women of learning.These warning signs will be ignored only at great peril.

For tins reason the Commission selected for its primaryattention the issue of eh hancing academic quality. During the

mrse of its deliberations many other related matters were alsoaddressed. The repot r presented here, however, deals onl% withthose issues directly connected with improving quality in highereducation and with strengthening public confidence in the na-tio His higher education in institutions. As a result, the report reflectsonly as portion of the Commission's actual work.

When issues arose that were recognized as being addressedby other agencies. the Commission judged that the most usefulcourse was to direct the Mid 10 bring the C(211111)1..0+1( )11 s !VC( )111-111endatitMs to the attention of the appropriate groups. Suchgroups include the carnegie Foundation for the Advancement of

Teaching which is studying extensively the need to improve rela-tions between the postsecondary community and those responsiHe for education in the schools. especially at the secondary level.The 1:( Rindat ion also continues to study and report on variousgo% ernance issues in higher education. Two other associations to

illch reCnIIMICIIII,III(WIN 11 ere given are the Association of Amen..can colleges and the AmeriL an Association of State Colleges and

imersins. both of A inch are pursuing studies and projectsconcerned with the redefinition of the meaning and purpose ofbaccalaureate degrees

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Higher education in the United States is characterized by avast ranw, of institutional settings. This diversity makes it difficultto formulate recommendations that are appropriate for all institu-tions. Moreover, given the contribution that higher educationmakes to this nation's well-being, the Commission might well havebeen tempted to formulate recommendations in language thatwould articulate to the public the significance ofthe educationalenterprise. But this report is written for policy shapers anddecision makers. The recommendations are not elaborately ar-gued since the issues are familiar to the community. It is hopedthat the conclusions of this knowledgeable group of commission-ers will be of assistance. Although the recommendations are statedin forthright terms, the members kept in mind that each institutionis unique and that few recommendations can be appropriate to allinstitutions.

The recommendations reflect a consensus of the Commis-sioners, but no particular member should be held accountable foreach recommendation. I am particularly grateful to each Commis-sioner for his or her dedication to the educational enterprise. Aschair of the drafting committee, Barry Munitz brought together thediscussions in an admirable fashion. In pursuing this task, he wasably associated with John B. Bennett of the American Council onEducation.

AcknowlCidgment is owed especially to Thomas M. Stauffer,.who served ,staff director for the Commission, for his creativesupport of the Commission's work. The ten higher educationassociations that participated in establishing the Commission in-cluded the American Association of Community and Junior Collleges, American Association of State Colleges and Universities,American Council on Education, Association ofAmerican Colleges,Association of American Universities, Association of GoverningBoards of Universities and Colleges, The Council of IndependentColleges, National Association for Equal Opportunity in HigherEducation, National Association of Independent Colleges and Uni-versities, and National Association of State Universities and Land-Grant Colleges.

The Commission members and staff gratefully acknowl-edge their debt of gratitude to the John D. and Catherine TMacArthur Foundation for the grant that made the deliberationspossible and express the hope that the results will prove advan-tageous to higher education.

Robben x: Fleming, chairNational Commission onHigher Education Issues

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Setting

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SUMMARYPriorities RECON1N1EN1ATIONS

and Strengthening .

AdministrativeLeadership

The Commission concluded that the greatest danger to quality inhigher education in the 1980s is "cuts-across-the-board." Highereducation has been on short rations for at least a decade. Certainlyfew programs are to he found that do not serve legitimate edu-cational needs. At most institutions, the obvious savings have beenmade. In many instances, reserves are being deeply eroded.future budgetary cuts will seriously jeopardize quality. If budgetsare further reduced, the critical question becomes how to reducethe scope of what is attempted. This practical approach is farpreferable to maintaining all existing programs but at a level thaterodes the quality of all.

The pressures to make cuts across the hoard are tremen-dous, in both the public and the independent sectors. Adminis-trators who take a little from all programs will run into lessresistance than will those who try to establish priorities. Yet evenover a relatively short period, the practices of the former are farmore likely than the latter to threaten the quality of the enterprise.

To counter these understandable pressures, the chief exec-utive of each institution should ensure that appropriate campusconstituencies are fully involved in the establishment and timelyreview of mission statements, role and scope documents, anddetailed strategic plans setting forth internal priorities. Resourcedistribution must follow these priorities, thereby reflecting andsecuring institutional objectives in a changing environment.Boards of trustee's, which have the ultimate responsibility forinstitutional priorities, should support the chief executive in mak-ing resource allocations that follow these priorities. Prioritiesaum,t; allocations are likely to be controversial, and unless theyare ace;led trustee support. -across tbe boardis- is likely toprevail and thus quality will be jeopardized.

LEADERS, 111) SELECHON

The methods of recruiting and selecting administrators, particu-larly chief executives, are open to substantial improvement. Con-

fidentiality is no longer the norm; many procedures arepoliticized; candidates are reluctant to expose themselves to theprocess; and tension has grown hetween faculty-based screeningcommittees and hoards of trustees. Increasingly, the names ofcandidates are released to the public prematurely and sometimesin an embarrassing (tanner. As a result,many highly 'civalifiedcandidates, especially sitting presidents at other institutions, nolonger are willing to allow their names to be considered. Theresult of all these impediments is a longer and more costlyselection process, limited candidate pools, and increased difficul-ties in eXCCLItiVC transition.

The Commission recommends that all persons involt.o.,d inthe search process should be instructed in the importance ofmaintaining confidentiality as a condition of their involvement.It further recommends that, to minimize the problem of breach ofconfidentiality, state legislatures should 'modify "sunshine lau,"

thty apply to the selection of biStilatiattal affietTS (lad jaCtiltylat'alberS.1

The COMIllititik mu fully endorses the need for formal selec-tion procedures and strongly supports the development of mean-ingful and productive affirmative action strategies to ensure thatwomen and minority candidateS are included,

The lay governing board is one of this nation's signalcontributions to quality higher education. It is important that thisbasic link between internal and external constituencies he asstrong as possible. Elected officials or nominating committees thatpropose names for membership on governing hoards of public orprivate colleges and universities should he sensitive to the essen-tial educational mission of these hoards. In public institutions,although partisan judgments and, indeed, political influence arerelevant to the selection process, trustees should be selectedfundamentally On the basis of their interest in, c'onc'ern far alaiability to so'm'e and higher' edttc'rttlou. Ally attempts toselect persons on the bask of factors irrelevant to academic valuesshould he resisted.

GOVERNANCE AND CENTRALIZATION

At a time of limited resources, the Commission rcmgnizes theneed both to husband resources and to respond to comfflunity andregional needs. Yet, its deliberations led to a healthy skepticismwith respect to centralization of authority in higher education and0 the conviction that quality may he jeopardized when decisionsabout academic programs are madi by agencies remote from

1 Lutittni,,,,,11 ttientht 1-tItt ard li +p.% Ow% th.t he into.t (11.p.,,t), late 111/Il+eltIn MI the ref ..111111tlidInt leg.if ding ,11thlentialitl in the h 1lrntes, And nit'tltttt.1gum nt ,t11).httit. 1.m,

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institutions. Concern was expressed that in sonic states authorityover institutions has become overly centralized.

6(wer)mrs am/ /twis/attires .lunaa review the current pat-tern of coordination to determine whether evolution (obi., cow.(lauding machine?). has led toward lowest-coinmost-denom Mato?.policies and destroyed the institutional flexibility that is required /to sustain quality programs.

The Commission recommends that governing boards en-Mire that all institutions under their jurisdiction have in placeprocedures for systematic program evaluation. Coordinatingagencies should, appropriately. see that all public institutions andthose independent institutions which receive direct state supportsubject their programs to a rigorous process of evaluation. 71n,actual program ent/tratimisslnitd, bmiret: he conducted at orbelow the letvl of the institutional gotyrn big hoard and shouldinclude extensity peer sroupiudgments.

Stat. s of statewide coordinating boards and other publicagencies concerned with higher education can, by wise and dip-lomatic prodding, become important components of the edu-cational governance structure. Thus, their staff members should heselected and compensated as befits their important role. Theyshould then be treated by university and college leaders in anopen and int.( wmative as partners rather than as adver-saries. The same openness sh( mid characterize the relationships ofinstitutional officers and faculties with state legislators andp)vernorN.

EnhancingQuality

and StrengtheningFinance

The relationship between quality and the adequacy of resources ismuch more subtle than that expressed h .t he proposition th.it thegreater the resources. the higher the quality. More money does nut

ass mean higher quality. and less money (Joys (1:It necessarilyreduce quality In the face of budgetary stringency, good institutions w ill be able to protect those activities of highest quality andrelevance to their nussii )11 clef ding \\ 'Itch other Ali% itieN to

eliminate.

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Nonetheless, quality is directly affected by not only thelevel but also the sources and stability of fupding. To be sure,institutions or programs that receive public funding must beaccountable for its use and provide the appropriate offices with,full and complete data. Still, the highest levels of quality andefficiency will be achieved only when each institution is givenmaximum freedom to allocate its funds with minimal externalinterference. The Commission recommends that those Nim allocute public funds provide incentives fin* efficient resnr rceLion and systematic etuluation of educational and managerialiffectit'eness.

The continuing health of America's independent and publiccolleges and universities is vital to the future of the nation, andeach is essential to the well-being of the other. Publ : colleges anduniversities and independent colleges and universities constitutean academic system that nourishes our country through its teach-ing, research, and service. The best interests of our nation areserved by supporting their respective needs and endeavors so thateach may contribute in its appropriate way. The federal and stategotrnments should take no steps that might impair the viabilityof this dual system in the years to come.

Both public and independent institutions are financed to avarying extent by students and their families, private philanthropy,the states, and the federal government. Multiple funding, by itsvery nature, is one of the strengths of American higher education.Examination4the various sources of funding by the Commissionled it to set fortryome expectations for each.

0

STATES

In addition to stable funding, the greatest contributu )11 states canmake to promote quality in the public institutions is to assure thattheir funding mechanisms are not overly enrollment- driven. For.minas based on en roll mons provide little lucent to improveprograms. .Similarly automatic yearend reversion of unopendeelappropriations Clieniagt'S Spending (111d diSOMMOS both re-SI)Un e ditierratif M and increased Oienty

State legiSlatilreS should (iMid linehhqn p()SUIHfrwitrols, cull other mechanisms that work against the general

principle of institutional flexibility within thy' framework ofaccountability. Such detailed budget requirements discourageeffective and efficient administration.

All states should consider following the practice of thenational government and those states that have established fundsfor the improvement of postsecondary education. These relativelymodest funds, distributed on a competitive basis to institutjons forspecial projects designed to enhance quality programs, haveproved to he most productive.

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THE FEDERAL GOVERNMENT

A vital federal responsibility in higher education is to provide astudent aid system that will assure access and choice to all qual-ified students. This responsibility is shared with families, students,and the states. I lowever, it is federa4 aid to students that largelyaccounts for the high rates of participation so essential to thecontinued health of the nations economy and the well-being Ofthe society. nic t mmitission is phrased Ill wile llw bowl/semsuppiripir theferleml r nle irr pnwiding student financial assist-ance am/ it rectal! mends a cuntinriin,t; somg federalttammimmi.

Federai primacy in the support of basic and applied re-search in universities preceded the griwth in the student aidsystem. Such support recognizes that progress in technology,pr(kluclyvity, and economic growth and advances in me(lical.sei-ence td space require that our universities have the capability tocarry- out that research. Yet, current grant and cost reimbuesementpolicies tail to cover the real costs to the institutions for theserose inch activities. /he ( (M///i/SS/mi recmiimendS Ma/ the ter/em/pirenimn/ OSP! Me a grealer leSMOISibilityjew the mainienonce(i/ 'v.:card) t apabilities at ma. ratiersilies.

.

PRIVATE PI IlLANTI.IROPY

Though investment income and gifts may not he large as aproportion of the total resource base for higher education, theyare indispensable and provide the vital margin for upholdingquality in many of ow- colleges and universities. Institutions mustbecome more sensitive to the changing needs of corporatkms forskilled personnel, and the corporations must increase their givingin recognition of the vital role that colleges and universities

intrihute to the health of the economy and to the quality of life inour country.

The interdependence between higher education and theprig ate business sector is much greater than is commonly recog-nized In fact, a strt mg national economy reflects, and is fundamen-tally dependent on. a strong community of higher education.Ace( )rdingly, h()//i cut,/ higher yam calm! shwa,/dm/ at t ())/ the wireahzed/nitentrra Pir eirhant ea t impeatum midrift reaseaprnductiil

STI 'DENTS AND FANIILIFS

0% er the next several vcars, it seems clear. the costs of highereducation %%ill continue to rise rnless existing financing sourcesare increased to meet these rising costs. tees %All! have to be

increased substantially at both public andindependent institu-tions, In that case. Inechanisins trill bare to be available to assistfilmilies. Specifically, institutions, banks, am! the government wiltneed to provide additional Pouts for student aid, in the form ofgnarls, ,cork- study monies, and loan capital. The Commission`'expressed grave concern about the,increasing numbers ofgraduating students who are burdened with heavy indebtOnessfor educational expenses.

SUNINIARYAssuring REcommEN

StandardsNo other issue consumed more of the Commission's debating timethan did the question of quality standards. But on no other issuewas there greater difficulty in reaching clear and conciserecommendations.

. It is easy to he dogmatic about raising institutional stand-ards. However, the strength of America's higher education lies inits diversity and in the jealously guarded autonomy of each institu-tion to experiml'nt and establish its own standards. The Commis-sion has no desire to urge recommendations that would under-mine institutional autonomy.

Additionally, the words "quality" and "excellence" can tooeasily become code words for excluding from the postsecondarycommunity all students except those who have had the advantagesof a strong college-preparatory education. It is also too easy toassume that "quality" means simply what happens when theacademically hest-qualified students are admitted to the mostprestigious institutions. Obviously, these narrow definitions arenot those of the Commission.

ACCREDITATION. AND DIPLOMA 'MILLS

The Commission endorses the present system of voluntary, nongovernmental accreditation, the center of higher education's self-regulation efforts. Howeve, the accnylitatum s.rstem, opeciallthe making bodies and etvtluating teams, should includemore efaMinkfrators andAC011y Members from hiSlifirliosknolen and respected far their high qualitx_Such person.k, shouldconsider it part of.their professional responsibilitym participate inthe accreditation process. Institutioilal accredit-ad( in processesshould focus greater attention on the integrity of academic de

Gsalmatk.

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grees. and particularly on institutional procedures for assuringthat graduates have mastered the basic academic competencies.

The Commission recommends that the Council on Postsec-ondar Accreditation be more vigorous in controlling the profferturn of specialized accrediting agencies. Although resources, fac-ulty salaries, office space, and other such matters are related to thequality of educational programs, specialized areditin,r4 agenciesshould JOcus on institutional procedures ji a* assuring that degreesare conferred only on students who have met stated requirements.Such matters as the allocation of resources, conditions of facultyservice, facilities, and administrative support should be left to thediscretion of institutimm.

State fiffiCiaLs, iewking With the EthiCatimi LuniitaSSimi ofthe States. should wnet their attack on diploma mills. which offeralleged academic degrees but require little or no work. TheEducation Commission of the States has developed model legisla-tion designed to thwart the operation of fraudulent institutions.Public confidence in legitimate institutions of higher educationwould he improved were all states to adopt and enforce such

Cl RIUCULt M

The Commission applauds the elk irts currently under war toimpro% e and strengthen undergraduate degree programs. Al-though it debated at some length a more precise definition of theasst and baccalaureate degrees, and explored the concept of-educational warranty." na clear consensus emerged other thanthe recognition that these remain vital issues and demand con-tinued study.

\Kith respect to the quality of undergraduate education. theCommission calls to the attention of colleges and universities theconcerns expressed b such nail( nil lit idles as the President'sCommission on Foreign Languages and International Studies, theKocketeller cominisskm on the I lumanines, the National ResearchCouncil. and the Association of American Colleges_ These bodieshate' concluded that, w ith few exceptions, the min( m's colleges andunnrsmes are not providing future chic, business, and prolesshift(' leaders w ith the understanding of foreign languages andcultures. of the rt )(Its of our ow n ci%ditation and culture. and of thepowers and hill itatimis of a ience and technolog% that they willneed to (am- out both public and private responsibilities The

nt tie's that these are exmg problems and urges thatthe nation s faculties and aullilnistrat( ffs. Ail cc)11cert w ith others.gi%e high pricwit% tu (c)rrccflun

//cc ronniicAan/ mic huh: that /in ytattent shwa(' ht'aanattea tic /patirm ht( citaareatvacNiccprnt;,«,11 N hr, (turn/ m ;01 fled poulamento 1 t mipctnt les in

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reading, writing, speaking, mathematical techniques. and Ivason-Mg. Colleges and universities should work with state high schoolofficials to establish the folk ming minimum units of high schoolstudy, or their GELD or other equivalent, for college preparation:four years of English, three years of mathematics and computation,two years of science, two years of foreign language, and three yearsdistributed among the social sciences and the humanities.

Colleges and universities share with the primary and sec-ondary levels responsibilities for helping to develop the compe-tence of those who do not meet the requirements for full partici-pation.in programs leading to the baccalaureate and who wish toacquire such competence, Such students should have access toremedial work and other appropriate assistance.

Likewise, for persons who wish to upgrade their careeropportunities and to advance their education, institutions mustmake it easier for them to participate in professional and continu-ing education programs. Such students should he allowed topursue their educational objectives without undue disruption andwithout having to take courses merely to certify knowledge andskills already mastered. hist/tut/m/s should eleelop clear criteria

Ineasuring and recotwi:ing previously attained competenciesand for linking measurement results to campus reqnirements Jordet,oveN4inil to proper placements of students in clethlt9IfiC pr.gra MS_Tefillfre h, Mak(' .arch pmvisi(ms dulls haywire mutswurnaers persumil. (mil public rem mrces

The future of higher education institutions is inextricablyhound with adult and continuing education. Lifelong learning ismore than a simple catch phrase. It has meaning and importanceto the individual and to society. It is a responsibility t)f highereducation, by both mission and role. Appnpriatemul timelyoljermgs should be provided, mu/ aileipuricjimmcia/suppHruurwhat icarm.Hg.,In mid he available.

The commission recognizes that perhaps one of the mostacute educational problems facing this nation one most directlyrelated to assuring quality in higher education -- is the need toimprt we the preparation of those who teach in the primary andsecondary Neho()k_ The issue' of recruiting and retaining the hestpossible teachers involves many factors other than their trainingduring college years, but it is this training for which colleges anduniversities are responsible. /be ( ommissinn Avis stomg/r thatti)th the atom-teHos fa/ the/n7,/cssmn ofteaching am/ toitherpre/him/if m IN* mast he improved Foundation support could heused to advantage in identifying appropriate strategies.

Certainly high priority should he given to eliminatingsubstan, l teacher education programs. Similarly, administratorsand members of appropriate higher educational institutions sh: )uld work with state pope) makers and appropriate rpre-sentat the elementary and secondary sat( d systems to

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ensure that teacher Cerhlicat m requirements are related to performance rather than to protection of the prolessk

ANI) POSITENUliE EVALUATION

/he ( Hu/miss/fa/ strimgl t. aPirws ti.)e con/inning imp/Jr/a/we oflacte/ty toriew (IS (Ill k'S011101 014,11111C111 10 111010C1 lie0(1(9111Cfire(1001. (Ma IherebY 11h. highest quality ill It'al110414 (111(111(.'(!1(1,. It endorses the description of tenure of the Commissionon AcaLlemic Tenure in I figher Education, a commissionsponsoreLl b the .1ssoiation of American Colleges am! theAmerican Association of University Professors:

An arrangement under %%nch faculty appointments in aninstitution of higher education are continued until retirementtor age or ph steal disahtlity. suhiect to dismissal for adequate(-Aim or unatoitlahle termination on account of financiale\ig,nt: . of elLinge of institutional program.'

That commission urged all institutions "to take prompt andigorous measures u) improve the operation of present tenure

plans in order to ctirrcut deficiencies which have becomeincreasingly apparent in recent yeArs- p.391. Since then manyinstitutions have tightened their evaluation procedures in linetit ith this recoinmendation. the time has oust' it (whimsadmim.stralit,as aml fatuities it, rTien- and. if ',ceded. rt1S0 their1».0tVal WS 0I'ller i/SA fire theMSefreS aila the pfathe (All the

it edfireS win prod/We/gib: rigor/MS. reienin/ eilanationS.hi the eveihratirm ullfacrelli. members. colt /irl('uti(llill' is

vsscutral If) hmik tamial assessments 1)1 pmlessimial (path:fi-ll( I I MS .\ SI:M..111CM of procedures by which academic judgmentsare.lul,ltit' should he open for inspection so that candidates andother members id educational communities can be assured thatthe processes ()le aill,ttR in pro% Ric tor toil Anti lair revio ofqualiticationN An at untie of redress should be available if impro-prieties in the process are belie% ed to have occurred, includingaidgments b,ised ill tactors of race. sex, or other irrelevantmatters (:andidates kir tacult% ad% anuement should be ant wdedthe 1)1),u-twin% to kil()W benefit from the dehher:ition ofpeers V\ lien these three principles Are incorporated into thero lett put icess, tontitlenthility protects the rigor And objectivity ofjut lgments

I The statement ()II c( Intidentialit% adopted by the Board ofI /IR% the American mncil t ill Education and :mother

t,11 OW NMI( stlhietl CillIM.SCLI h% the mmhership of the

1 r . 1.1,-11). \XIII! III) K he tt tr:/i lcItrr,t 1

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Association of American Universities provide more elaboratecomments On this important matter.2

Academic tenure is not a guarantee of a job ffir life short ofdisability or economic disaster. In the judgment of the Commis.Sion, lotbikt; (('ill undermine 11w tenure Srsteln Priory completelythan its being regarded as a system to protect faculty e'lbeS.1.1'0M OW111(1110)15. Although the burden is oil the institution todemonstrate "adequate cause" by peer-group judgments, "demon-strated incompetency" is adequate cause for dismissal.

caMpUS deadt'M le administrators. working closely uithappropriate faculty omittcws. should develop a system ofpas/tenure evaluation. The process should provide for periodicpeer-group reviews to assure that the tenured faculty has main-tained the appropriate level of competence and is performing at asatisfactory level. When equitable procedures identity facultymembers of "demonstrated incompetency," the administration andfaculty's responsibility is to see that the particular problem isremedied and not glossed over. Incompetent faculty membersmust not be protected at the expense of the students or themaintenance of quality.

Likewise, campuses should devise and implement galarprocedures for etaluatinj; academic administrators. Such eVailla-h011S should he timely and thorough, and Should id)1.1. pr.( wide for theprofessional development of the incumbents under review as wellas for the improvement of overall organizational efficiency.

FACULTY SALARIES

Academic salaries have not kept pace with inflation. The resultingdecline in standard of living, coupled with a reduction in supportfor research opportunities, especially for faculty members in tilt'humanities, has affected morale. Inadequate compensatn in makesit difficult to attract and retain many talented persons, particularlyin fields where academic salaries are unreasonably noncompeti-tive with those in the private enterprise sector Lower moralegenerates a St'llsC () negati ism toward the academic enterpriseThe resulting threat to quality is clear. !het fonlMiSSifoll t r,itt'mis!ha bit fair Sahffit'S i.c 01M ollg Iht higher priualt5 illthe 0110C0ilf )11 (of 1125MOVCS

In the all( ament of salary funds. the Commission rectmlincnds that taciair ((ill/pet/Pit/Mt shtoid/r/ be based primaril mMerit 05 defer1111 h{'0 Crirefill pevr-grroup iulin istratu

fo, individual accomplishments. I ugh inflation and

2 rhr qatrint-nts .11u inttlkit'llt1.1111% tit 1 Ili% %Al% I al tilts .1,.1ppr,yrt itt- Ii. )1t: ut Iti,tilitrwn.11 althmigh tilt. IV... M, siSituf CW1.111..11If

I ilt' At I B...ird .16 ,dirty +Lilt:111M at 19MI.111c \ 11 .Iht rt+ intmht.r,hip .It it, ;Intl 17142 mcling

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equity considerations may justify salary increases by category oraccording to time in grade; still, profess/ mull incentives antiingli !ere/ poformance are.jeopaoyiized by compensation programs that MI to take aCcolint of indit'itial peVinallti.

COLLECTIVE BARGAINING

Collective bargaining as an established feature of American life iswidespread 3111( ng craft workers, industrial workers, health serv-ice employees, white- collar workers in commerce, and employeesin the public service. In higher education, it has developed morerecently among faculties, though it has king been used by supportstaff employees. Its effect on institutional quality is still uncertain,if hotly debated. Several things are, however, clear. (a) The debatewill continue, and the verdict about the effects of collectivebargaining on the academic enterprise remains in question. (b)Collective bargaining as a process is both legitimate and within therights of faculties to pursue. (c ) Both institutional administratorsand faculty leaders are relatively unversed in the process, com-pared with other sectors, and should take pains to prepare them-selves well if collective bargaining is contemplated. (d) Collectivebargaining is a highly serious step in faculty-administration rela-tions, and those in institutions where bargaining is in the offingshould closely examine the experience in other institutions wherefaculties bargain collectively to see what changes in relationshipsmay occur. And (e) Both the administration and faculty in aninstitution with collective bargaining will be unfaithful to theirprimary obligationthe conduct of high-quality teaching, re-search, and serviceif they incorporate in their negotiatedcontracts provisions that impede fulfillment of that obligation.

Agenda forthe Future

tontmued eltare the l'mted Mates is tied inextricably to itshigher education institutions. Strong colleges and universities areintegral to the nation.s vigor --economically, culturally, evenspa tialh In an increasingly knoyledgebased stkiety, the im-portance ot that relationship can only grow. Recent decades havew 'messed sharp expansion in college enrollment,. institutionalbudgets. and university research acti% uses. This growth has beenno Ct iefent. sinc complex technical societies need equally com-plx higher educational resources Prsperity in such societiesrests upon healthy colleges and universtrws.

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The Commission's focused agenda for continued qualitat 'egrowth is reasonable and actionable. It calls upon every campusadministrator, board member, and public official to advancehigher education's welfare and to address strengthening its quality:Acting on the Commission's recommendations, higher educationcan attain a greater sense of purpose and forward movement. Mostcritically, students and society will benefit from this modest butfirm commitment.

The National Commission on I ligher Education Issues offers its recommendations in the firm belief that higher educationcan participate effectively in leadership of the nation and theworld. Academicians confront in the agenda offered by this reportsignificant opportunities to benefit humankind and, at the sametime, to gain a renewed sense of direction and dedication forthemselves.

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Mr. SIMON. Thank you very much and all three formal state-ments will be entered into the record.

Dr. Millard.

STATEMENT OF RICHARD MILLARD, EXECUTIVE DIRECTOR, THECOUNCIL ON POSTSECONDARY ACCREDITATION

Mr. MILIAttD. Thank you very much. My full statement is availa-ble to you. I think I had better back up a little and talk about thenature of accreditation, what it does, what the Council does, andthen react to some aspects of the Carnegie report.

First, I would like to start by.saying that accreditation is the pri-mary communal self-regulatory means of academic and profession-al educational quality assessment.

It is, as the Carnegie report points out, a crucial part of academicand professional governance. Accreditation as a status is granted toan educational institution or program that has been found by itspeers, including professional and public representatives, to meetstated criteria bearing on educati cal quality and accomplishment.

Accreditation as a process has t o fundamental purposes: To cer-tify the quality of an institution r program and to assist in thefurther improvement of such quapty. What accreditation attests tois that an institution or a program has clearly defined an educa-tionally appropriate objective, that it maintains conditions underwhich their achievement reasonably can be expected, that it ap-pears, in fact, to be accomplishing them substantially, and that itcan be expected to continue to do so.

There are two types of accreditation, as has already been pointedout. Institutional and specialized or programmatic, Institutional ac-creditation is carried out by accrediting associations which are na-tional or regional in scope. It focuses on an institution as a whole,and thus gives attention not only to the educational program, butto such areas as effective management and administrativestrength, enlightened personnel policies, financial and physical re-sources, student personnel services/ and consumer protection.

COPA recognizes 13 institutional accrediting bodies, includingthe nine regional commissions, and four national institutional ac-crediting bodies which accredit special types of separate institu-tions: business, trade and technical, home study, and Bible.

Specialized accreditation is carried out by accrediting associ-ations within specific professional or occupational fields. Special-ized accrediting associations accredit programs or schools in com-plex, institutionally accredited institutions which prepare profes-sionals, technicians, or members of special occupations, and insome cases, single-purpose, freestanding professional schools inthese areas, in fact, in a good many cases.

Through their relations to professional associations, they areable to provide not only assurance that the program is educational-ly sound, but also that it is relevant to the current practices in thefield. COPA recognizes 37 specialized associations.

Now, the Council on Postsecondary Accreditation is an integralpart of the total self-regulatory process. It is a voluntary organiza-tion of accrediting associations and national postsecondary educa-tional organizations designed to carry out three objectives. The

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first is to recognize accrediting associations that accredit institu-tions and programs on the basis of demonstrated need and specifiedstandards.

The second is to provide national leadership and understandingin speaking for accreditation, and the third is to provide services tothe accrediting associations, the educational institutions and thepublic, by assisting and improving the general accrediting process,as well as the policies and practices of recognized accrediting asso-ciations, facilitating coordination among accrediting associations,and encouraging and conducting research relating to understand-ing and improvement of accreditation.

The Council consists of a board of 15 elected and 4 ex officiomembers, and 3 assemblies: An Assembly of Institutional Ac-crediting Bodies; an Assembly. of Specialized Accrediting Bodies;and an Assembly of National Postsecondary Education Organiza-tions.

The Council is the primary means of providing self-regulatory ac-countability of the accrediting community to the academic and pro-fessional communities and the general public. The Council's func-tions are broader and differ considerably from the Federal recogni-tion process carried out by the Secretary. The latter is primarilyrelated to determination of institution and programmatic eligibilityfor Federal funds.

Over the past 2 years, the relations between the Council and theDepartment of Education, including the eligibility and agency oval -

. uation staff, have been cordial and cooperative.Secretary Bell and Mr. Richard Rowe have encouraged and rein-

forced this cooperation. We strongly believe, as Dr. Peltason haspointed out, that nongovernmental voluntary accreditation of insti-tutions should continue to be a major condition of institutional eli-gibility for Federal funds.

The self-regulatory mechanism of accreditation not only insuresthat quality judgments are made by qualified peers in the publicinterest, but is in harmony with the national emphasis on in-creased self-regulation in contrast to governmental regulation.

Mr. SIMON. Dr. Millard, I hate to interrupt you. We, unfortunate-ly, are going to have in about 28 minutes a meeting of our full com-mittee. We are going to enter the rest of your statement in therecord.

[The prepared statement of Richard Millard follows:]

EXECUTIVE SUMMARY OF TESTIMONY FOR THE SUBCOMMITTEE ON POSTSECONDARYACCREDITATION BY RICHARD M. MILLARD

I. Accreditation is the primary communal self-regulatory means of academic andprofessional educational quality assessment and enhancement. Accreditation atteststhat an institution or program has educationally appropriate objectives, maintainsconditions for their attainment, is accomplishing them substantially, and can he.ex-pected to continue to do so.

2. There are two types of accreditation and accrediting associations: (1) institution-al, which focuses on an institution as a whole including fiscal integrity, administra-tive strength, student services and consumer protection and, (2) specialized, whichconcentrates on specific occupational and professional fields in accredited institu-tions.

3. The Council on Postsecondary Accreditation (COPA) is a voluntary organizationof accrediting associations and national higher education organizations designed to(1) recognize accrediting associations, (2) serve as a national locus and voice for ac-

72

creditaton, and (3) assist in improving accrediting processes and standards and co-ordinating the activities of accrediting associations.

4. Voluntary accreditation should continue to be a major condition of eligibilityfor federal funds. Government involvement should be limited to eligibility for feder-al funds and should not be broadened to more extensive oversight of accrediting ac-tivities.

5. The Carnegie report is on target in recognizing the critical role of accreditationin academic governance and of specialized accreditation in maintaining excellencein the quality of the professions they serve. It rightly calls on all senior college offi-cials to participate actively both in institutional and specialized accreditation. Thereport's contention that institutional accrediting bodies neglect undergraduate edu-cation is open to question. The important role of national as well as regional institu-tional accrediting bodies should be taken into account in considering institutionalaccreditation and its uses.

6. The report tends to over-generalize the "threat" of specialized accrediting asso-f-ciations to the "the integrity of the campus" and overlooks the increasing use of

educational outcomes by specialized associations in determining educational quality.It does, however, reinforce COPA's concerns and activities in encouraging coordinat-ed visits and information sharing.

7. Institutions can and do inform CO,PA of problems and COPA has procedures fortheir investigation and resolution. Third party testimony including testimony frominstitutions are utilized in the recognition processthus fulfilling the spirit of theCarnegie recommendation on appeals.

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PREPARED STATEMENT OF RICHARD M. MILLARD. EXECUTIVE DIRECTOR,THE COUNCIL ON POSTSECONDARY ACCREDITATION

I am Richard Millard, President of the Council on Postsecondary Accreditation.

I appreciate the opportunity to appear before the Committee on behalf of the

constituent members of the Council. These include 50 recognized institutional

and specialised accrediting associations, 7 institutionally based higher

education organizations, and through these members the 4100 accredited insti-

tutions in the United States.

Accreditation plays a crucial role in assessing whether an institution or

program has accepted and is carrying out its commitment to quality and in

providing incentives to encourage quality enhiincement. Accreditation is the

primary communal self-regulatory means of academic and professional educational

quality assessment. It is, as the Carnegie Foundation for the Advancement of

Teaching report, The Control of The Campus, points out, a crucial part of

academic and professional self-governance. Accreditatiorlas a status is

granted to an educational institution or program that has been found by its

peers, including professional and public representatives, to meet stated

criteria bearing on educational quality and accomplishment. Accreditation

as a process has two fundamental purposes: to certify the quality of an

institution or program and to assist in the further improvement of such

quality. As an activity accreditation can be described as the members of

the academic and professional community working together to develop and

validate standards, to assess the adequacy of their operations in the light

of these, and to offer peer judgment and guidance to assure students and

the general public of ci.a integrity and quality of education offered.

74

What accreditation attests to is that an institution or program has clearly

defined and educationally appropriate objectives, that it maintains conditions

under which their achievement reasonably can be expected, that it appears in

fact to be accomplishing them substantially, and that it can be expected to

continue to do Accreditation is accomplished through accrediting assoc-

iations which consist of institutions, programs, professional groups and their

representatives, plus representatives of the public. The process of accredi-

tation involves goal definition, self-study, peer review and judgment by the

appropriate accrediting, commission, board, or committee.

There are two types of accreditation and accrediting associations, institutional

and specialized or programmatic. Institutional accreditation is carried out by

institutional accrediting associations which are national or regional in scope.

Institutional accreditation focuses on an institution.as a whole and thus gives

attention not only to the educational program but to such areas as effective

management and administrative strength, enlightened personnel policies,

financial and physical resources, student personnel services, and consumer

protection. The Council on Postsecondary Accreditation recognizes 13 institu-

tional accrediting bod es including the 9 regional commissions and 4 national

institutional accredititg,lattLiaa,hich accredit special types of separate

institutions (business, trade and technical, home study and bible).

Specialized accreditation is carried out by accrediting associations within

specific professional or occupational fields which usually are closely related

not only to the educational programs and to the professional associations in

these areas. Specialized accrediting associations accredit programs or schools

in complex institutions which prepare professionals, technicians, or members

of special occupations and in some cases single purpose free-standing

professional schools in these areas. Specialized associations require that

7L

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the programs they evaluate, except for free-standing schools, be part of an

institutionally accredited college or university. Through their relations

to professional associations they are able to provide not only assurance that

the program is educationally sound but also that it is relevant to current

practices in the field. The Council on Postsecondary Accreditation recognizes

37 specialized associations.

The Council on Postsecondary Accreditation is an integral part of the total

self-regulatory process. It is a voluntary organization of accrediting

associations and national postsecondary educational organizations designed

to carry out three objectives: the first is to recognize accrediting assoc-

iations that accredit postsecondary institutions and programs on the basis

of demonstrated need and specified criteria related to accrediting policies

and practices. The second is to provide national leadership and understanding

in speaking for accreditation. The third is to provide service to the

accrediting associations, postsecondary educational institutions and the

public by assisting in improving the general accrediting process as well as

the policies and practices of recognized accrediting associations, facil-

itating coordination among accrediting association, and encouraging sand

conducting research relating to the understanding and improvement of

accreditation.

The Coven consists of three assemblies: an Assembly of Institutional

Accrediting Bodies; an Assembly of Specialized Accrediting Bodies; and an

Assembly of National Postsecondary Educational Organizations. It is

governed by a Board with IS members elected by the Assemblies except. for

members at large and public members, who are nominated by the Assemblies

but elected by the Board, and 4 ex-officio members including the chairman

of the three Assemblies and the President of the Council. The 9 members

S* " .

k k' t\

%\k.);

76

of the crucial recognition committee, with the exception of the chairman, are

non-board members including 2 public members nominated by the Assemblies and

elected by the Board.

The Council was formed in 1975 b merger of the National Commission on

Accrediting and the Federation of Regional Accrediting Commission* on Nigher

Education. One reason for the merger was the realization that to insure the

integrity and strength of accreditation the accrediting and higher education

communities must work together through self-regulation to improve the

accrediting process and to apply common high standards to'the recognition

of member accrediting associations. The Council is the primary means of

providing self-regulatory accountability of the accrediting community to the

academic and professional communities and to the general public.

The Council's functions are broader and differ considerably from the federal

recognition process carried out by the Secretary. The latter is primarily

related to determination of institutional and programmatic eligibility for

federal funds. I am happy to report that over the last two years the re-

lationship between the Council and the Department of Education, including

the Eligibility and Agency Evaluation Staff, has been cordial and cooperative.

Secretary Bell and Mr. Richard Rowe have encouraged pd reinforced thissr

cooperation.

We strongly believe that non-governmental v luntary accreditation of institu-

tions should continue to be a major conditi'n of institutional eligibility

for federal funds. This assures that federa funds go to institutions that

meet the quality requirements of the academi community. The self-regulatory

mechanism of accreditation not only insures that quality judgments are made

by qualified peers in the public interest and is highly cost effective but

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is in harmony with the national emphasis on increased self-regulation in

contrast to governmental regulation. It is important that government in-

volvement be limited to eligibility for federal funds and not be broadened

to more extensive oversight of accrediting activities.

Accreditation is carried out by literally hundreds of volunteers across the

Country. While it has its problems, on the whole, it has worked well in .the

service of the academic community and the nation. We are, however, concerned

with strengthening accreditation in every way possible. The report of the

Carnegie Foundation on the governance of higher education is timely and in

many ways will help to facilitate the work of the accrediting associations

and the Council on Postsecondary Accrpditation. Its recognition of the

critically important role of accreditation indocademic governance is most

welcome, as is its statement in relation to specialized accreditation that

"we share their interest in maintaining excellence in the quality of the

professions they serve". Where abuses occur in any form of accreditation

they must be corrected and we are committed to work with the accrediting

associations and the national higher educational associations to identify

and correct these. The admonition that "senior officials at all colleges

and universities should fully support their accrediting associations and

participate actively in their work" has the full endorsement of the

accrediting community and is crucial to the strengthening of accreditation

in all itsNforms. There is evidence, however, that there is currently

considerably "re such involvement of major institutions than the report

would suggest. .\Furthet, the report does not adequately recognize that this

call for involveMent is or should be as applicable to specialized as to

institutional accreditation. While specialized accrediting associations

include members of the professions and their associations, in every case

their accrediting commissions and visiting teams also include educators

A 22-141 0-84--6

78

and institutional representatives.

The report suggests that institutions accrediting associations have

neglected undergraduate education. The fact is that 62.32 of regionally

accredited institutions are undergraduate only and another 23.22 offer

baccalaureate and masters programs only. All of the regional commissions

assess the adequacy of curriculum in the light of institutional mission.

Not to take Into aeeount uniqueness of mission would be to negate

legitimate diversity and to impose the very interference in the prerog-

atives of institutions in curriculum developent to which the Carnegie

report as a whole so eloquently and rightly objects.

The report should have noted that in addition to the regional Commissions

the four national institutional accrediting bodies that carry out equally

effective accrediting activities in their respective areas must be taken

into account in any considerations of institutional accreditation and its

Uses.

That regional and other institutional accrediting bodies should hold insti-

tutions accountable for good management, enlightened personnel policies,

educational results and cunsumer protection as the report recoma.mds is

However, to make this as a recommendation overlooks the fact that

they do so now. All of the factors are currently included in institu-

tional accrediting criteria. Perhaps the recommendation might well be that

emphasis on these factors should be further strengthened, but what is now

being done needs to be recognized.

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That there have been instances of overly specific and intrusive requirements

by specialized accrediting associations, even cases where the interests of

the professions have dominated over concern with the campus as a whole, would

be hard to deny. However, to imply that all or most specialized accreditation

"threatens the integrity of the campus" is in fact a generalization that

would be difficult to justify or document. It is also true that the number

of specialized accrediting associations has increased over the past thirty

years but this is a function of an increasing number of professions and

occupations where issues of public welfare, health, safety and need for

assurance of professional competence are matters of academic and public

concern. In fact the number of specialized accrediting associations rec-

ognized by the Council on Postsecondary Accreditation has decreased from 39

in 1977 to 37 today. The associations in the Assembly of Specialized

Accrediting Bodies not only are cognizant of the problems but in cooperation

with the Council are addressing them.

In a number of areas involving specialized accreditation the report reinforces

efforts currently underway and we welcome this reinforcement. 1n relation to

institutional integrity and autonomy the COPA recognition criteria specify

that an accrediting association (1) "develops and interprets its criteria to

allow and encourage institutional freedom and autonomy" and (2) "examines

and evaluates institutions or programs in relation to operational goals of

the total institution and to educational outcomes". COPA is working with the

accrediting associations to insure more effective compliance with each. Major

steps have been taken by the specialized and institutional associations to

encourage interagency cooperation and coordination, but to be effective this

also requires institutional cooperation. It should he added tho: some of the

specialized accrediting associations nut only have under study but are making

substantial progress the further utilization of educational outcomes in

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determining educational quality.

One of the recommendations of the report calls on the Council on Postsecondary

Accreditationyo organize and maintain an appeals process to,resolve conflicts

when an institution believes it has been unfairly treated by an accrediting

association. Currently each recognized accrediting association as a condition

of recognition must and does have a fully developed and adequate appeals

procedure of its own. COPA obviously is not the forum for any quasi-judicial

review of individual accrediting decisions. However, the Council fulfills

the intent of the recommendation. It has a formal complaint procedure for

institutions which provides for review and resolution. Institutions not only

may but do frequently report to the Council problems they have with the

accreditation process. During the recognition process third,party testimony

is solicited and any institution may submit such testimony on which the

association may comment but which is taken into account in the recognition

review. Further, the Council is currently considering the possibility of

developing a system whereby each institution may send evaluations of

accrediting activities bOth to the accrediting association and to the Council,

Most accrediting associations including all of the regionals now provide

for evaluative reviews. Finally, the higher education organizations in the

Assembly of National Postsecondary Educational Organizations provide an

additional institutional point of view in the determinations of the Council.

Thus, there is no danger of institutional concerns going unrepresented or

being left our of account.

In summary, the thrust of the recommendations in the Carnegie report on the

whole are timely and helpful and call attention to the importance of

accreditation. Some are already being carried out; others add to or

stimulate discussion of the issues; and some need to be viewed in the light

of wiat has already been accomplished.

Again, I want to express my appreciation for the opportunity of testifying

'before the Committee. I sincerely believe that the future quality, health,

and integrity of postsecondary education in this country is intimately

related to the effectiveness of the communal self-regulatory assessment

and enhancement of quality which is voluntary, non-governmental accreditation.

81

Mr. SIMON. I think in order to make this a fruitful discussion, Iwould like to move, if we could, to questions.

So, I understand where we are, I read just the other day in the"Chronicle of Higher Education" where Boston University hasitsjournalism school has lost, or I am not sure whether it is voluntaryor what, but they are losing their accreditation.

Now, No. 1, does the Federal GovernmentI recognize that wehave to, through the accrediting agencies, recognize the school, butdoes the Federal Government, No. 1, recognize that journalism as-sociation in addition to the overall association; and No. 2, how doessomething like that impact on Boston University, and how is theFederal Government involved there?

Mr. MILLARD. I cannot tell you whether in that particular casethat specialized accrediting agency is on the list, or not.

Mr. B0YER. It is.Mr. MILLARD. It is?Mr. BOYER. In the back of our report, Mr. Chairman, page 93, ap-ndix A, you will see the list of those associations that are on thecretary's list of approved accrediting bodies, and eenie, mince,

mince, mu.Mr. SIMON. At 24, I see.Mr. BOYER. Twenty-four is the Accrediting Council on education

and journalism and mass communications, which I think almostwithout. exception would be a subunit within a regionally accred-ited institution.

It is a clear example of where I think we have made accreditingthe accrediting bodies, rather than asking what is the threshold ac-tivity by which we have to insure that an institution is legitimatel-ly able to receive Federal funds.

Make the point in your own example. Suppose the journalismschool at BU does not get accredited? Does that mean Boston Uni-versity is now not eligible to get student aid, or to get grants fromthe Department of Defense? The answer is "No."

Yet, we have been partner in giving that organization licensefrom the Secretary to carry out its mission. It could still do it, butthe point is we have added a Federal authority, and a Federal stat-ure to that, what I consider to be voluntary effort.

Mr. PELTASON. Can I just make a comment about that?Mr. SIMON. Yes.Mr. PELTASON. As an example, very briefly, because one of the

most distinguished journalist schools in the country recently re-fused to he accredited by a journalism association. The issue wasthe salary of the professors. The president of the institution tookthe position that the issue before the journalism accrediting teamare these good professors, not only the rich professors.

By refusing to give them the information, they were not accred-ited. That is a very distinguished school and in this particular case,its reputation is sr; great that it did not make any difference, andbecause of the first amendment, journalists are not licensed.

However, if you have a licensed profession and they should askthe same question, the institution would be at a greater disadvan-tage because if it refused to be accredited because it thought it wasan improper intrusion into the autonomy of the institution, itsgraduates might then suffer a disadvantage because they might not

82

be able to stand for the bar exam, or the county exam, or someother kind of exam.

That is where licensing and accreditation get mixed.Mr. SIMON. Yes; go ahead, Dr. Millard.Mr. MILLARD. I think, though, you have to keep two or three

things in mind. It may well be the case that journalism is one ofour recognized agencies and one of the recognized agencies by theCommissioner. I think the issue, though, that has to be kept inmind in looking at special accreditation is pointed out by the Car-negie report, where it says, "We share their interest in maintain-

ling excellence in the quality of the professions they serve."I think it would be a mistake to prejudge the journalism situa-

tion or a number of the others. You asked earlier about how ac-creditation, or I think Mr. Packard did, about how accreditationtakes place and who establishes the standards?

I am not in the position of attempting to defend journalism oranyone else at this particular point, but the way the accrediting as-sociations work, and they go back historically even further thanthe regional associations, it is through a cooperative effort betweenthe members of the profession, and the institutions and programsinvolved. Their concern is with the adequacy of the program inlight of two things: One, its quality within the institution; and two,its effectiveness in preparing people for the profession.

I think this has to be kept very clearly in mind. I am not sug-gesting that it is necessarily the function of the Secretary to recog-nize them. But I think to understand the importance of specializedaccreditation is very important.

Mr. SIMON. If I can interrupt, I do not think the question iswhether this association is doing a good job or a had job, and myassumption is that they are doing a good job, and that generallytheir suggestions are good suggestions.

The question really is, should the Federal Government be in-volved in recognizing this kind of an association? Now, in somecases, to use the case you used, Dr. Boyer, in the school of podiatry,you almost have to get into a very specialized kind of a thing andthe Federal Government has no choice.

Mr. MILLARD. Incidentally, it was chiropractic.Mr. SIMON. Yes; and there are other examples, but I guess myinstinct is, No. 1, no journalism at either Northwestern or Boston

University is going to lose their student aid because of the lack ofaccreditation, or that is the assumption I make anyway; is that cor-rect?

Mr. BUYER. That is correct.A" r. MILLARD. Right.

PELTASON. Yes, it is, sir.Mr. SIMON. OK. So, that there is a question of how much good it

dor s in the first place. Second, there is a question of whether weought to be involved in that kind of minutia at the Federal level. Itgets to Steve Gunderson's earlier question.

Mr. BOYER. That is why, if I might say, Mr. Chairman, it seemsto me the question before a2 committee, if I may be so bold, atleast from the Federal rule is, what is the minimum obligation thatshould be taken here to protect and where do we go beyond thatand engage ourselves in becoming the approver of all accrediting

83

agencies, whether or not ,they are essential in establishing eligibil-ity for Federal funds.

That is an important line that I think provides a threshold fordebate and I have to tell you that from my experience, and I amnot speaking of people who are ill-willed, but that operation withingovernment has determined its mission to be the approval of allbodies that wish to be recognized as accrediting bodies, irrespectiveof whether they are essential to perform that threshold function ofprotecting eligibility for student funds.

That, to me, is a very important distinction to be drawn and asyou just said, this has nothing to do with whether a given accredit-ing association is doing a good job or not doing a good job. In fact, Ido not even think that should be a discussion for a Federal agency,save are we finding a way to sort out the good institutions from thebad ones who get the Federal money.

Mr. SIMON. Mr. Coleman.Mr. COLEMAN. Mr. Boyer, in your remarks, you indicated, you

drew in the delinquency issue on loans and so forth. Are you sug-gesting that accreditation is or is there a criteria for accreditationon an institutional basis of whether or not the institution has paidback government loans and what the delinquency rate of their stu-dent loans in existence might be?

Were you trying to equate that delinquency or bad characterwith the fact that they were or were not accredited. Is there a con-nection?

Mr. BOYER. As I was suggesting even under the best of efforts ac-cording to the current criteria, when you have an accredited col-lege, you still do not give the Administrator here in Washingtonany assurance that he is off the hook in terms of whether they aregoing to use that money well.

So, we,have here a problem of whether even minimum criteriainvolving -a Federal agency is going to give protection and I illus-trated the ftzq that all of the colleges that I know of that had highdefault rates, including some that had 89- and 85- and 90-percentdefault, had at least one accredited recognition which causes theCommissioner and Secretary to sleep well at night and say, "Well,they are accredited, no more defaults."

Well, that is just not the case, the point being that in the end,good administration still means you have to monitor performance.Now, we have talked in our report about whether regional accredit-ing, and I point to you, Jack, whether the institutions should notbe asking the same kinds of questions when they regionally accred-it that the Secretary has to ask when he is accountable to you.

Namely, do you have default rates and why? Do_you have affirm-ative action? If you do not, why? Those are the Federal concerns,but ironically most of the criteria that we use now to establish eli-gibility for accreditation, and I must say most of the criteria usedby the regional bodies to accredit, do not come to terms with theaccountability standards that the Federal agencies are concernedabout.

There are primarily two: Fiscal accountability and equity interms of treatment of individuals.

Mr. COLEMAN. I would like to hear from the gentleman fromCOMA, then.

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Mr. MILLARD. I think you have to make an important distinction.At the present time, all of the regional agencies do, and the institu-tional agencies, do look at a series of things. They look at the fiscalintegrity, at the administrative strength, at the personnel services,at the adequacy of the structure for handling these issues.

Now there is an important distinction that has to be drawn interms of day-to-day policing in this respect. The accrediting agency,by the nature of the case, cannot do that. If, there are adequatecomplaints and so on, or if there are complaints, the accreditingagency can go back in, but accreditation is carried out by a systemof volunteers, the staffs are relatively small, there is a tremendousamount of time that is devoted to it., The accrediting associations do look carefully at the conditions

whik,h would be desirable and essential if the institution is to carrythrough its fiscal and other commitments.

What it probably cannot do is engage in a detailed audit of therecords. This is something that is not within the function of the accrediting association. Each of the accrediting associations do, how-ever, at the time of accreditation, or at the time of review, ask fora complete audit of the institution, fiscally as well as otherwise.

In this sense, the associations, even in relationship to affirmativeaction, do not have as a part of the accrediting agency function, theauthority to insist on a specific formula and so on. In every case,the regionals do look, among other things, at the structure of the\fairness of employment within the institution.

Now this is a different thing from saying that the accreditingagencies should police on a continuous basis. This they cannot do.They can assure, however, at least offer reasonable assurance, thatthe structure is such that it is conducive to effective management.

Mr. SIMON. Mr. Kogovsek.Mr. KOGOVSEK. Thank you, Mr. Chairman.For anybody on the panel, I guess this has been a subconscious

fear that I have had over the years that accrediting agencies havebeen used to control small versus large.

Let me explain what I mean about that. It seems to me thatsome of the large institutions, State institutions, whether they arein Colorado or California or wherever, have an easier time of get-ting accredited year after year than s6me of the small institutions.I guess funding comes in here.

Is my fear warranted at all?Mr. PELTASON. I understand your fear, but I do not think the evi-

dence can support it. There are 3,000 colleges and universities ofall sizes, of all different philosophies, public, private, some tradi-tional, some experimental, and that is where accreditation, I think,is adapted to America's kind of higher education and pluralisticsystem.

It is not perfect, it gets charged both with having too rigid stand-ards and then in the next breath, not hEr4:ig sufficient standards.But I do not think there is any evidence. I think it is probably ac-curate to say that an institution of international fame and distinc-tion will be subject to less detailed scrutiny than a brand new onejust starting ,:ut with nontraditional experimental modes, but itseems to me that that is a reasonable assumption to make.

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Mr. KOGOVSEK. Let me just ask Dr. Boyer, as part of your report,you contend that higher education professionals are not taking ac-creditation seriously enough. Do you have any statistics on whatpercentage of individuals in academia actually participate in theaccreditation process?

Mr. BOYER. No, I do not. I am sorry. Mr. Millard may know moreabout that than I, but it does give me an opening to make the fol-lowing point. While I have tried, on this occasion, to explain what Ithought might be more appropriate limits on Government involve-ment, the weight of our document is to say to the higher educationcommunity, this is an obligation you must take more seriously.

That is the overriding weight, so there is a two-sided debate here.I feel strongly that there should be a sharper focus here in Wash-ington as to how accreditation is assessed, but the flip side of thatis universities and colleges and accrediting associations had betterstep up to the implications.

To comment on Mr. Millard's point, if we are not able to tell theSecretary of Education that we can, through accreditation, hold in-stitutions accountable for defaults, if we cannot say that we aregoing to see to it that they are clear and effective in their affirma-tive action, I see no other response except that the Federal officerwill have to give his own oversight which I think has in it seeds ofgreat danger.

To answer your question, our interviews suggested that especial-ly senior academic officersI mean by that, ranking college presi-dents and the likeare not as active as they once were and thishas tended to, in my judgment, diminish the significance and theimportance of self-policing.

I believe the importance of self-policing has to come from themost outstanding university and college leaders in the country so itsays to the Nation, we can manage our own affairs. I have a feelingif we do not make that statement, then clearly the officers whoreport to you are going to have to figure out ways to do it on theirown.

Dick may know more about the percentage of participationthan I.Mr. MILLARD. I would certainly agree with Dr. Boyer on the im-

portance of the involvement of chief executive officers of the majorinstitutions, as well as the lesser institutions. I think it would befair to say that there are sonic institutions that have not acceptedthe responsibility in the past.

I think on the other hand, I can point to the effective involve-ment of many institutions, both through their own regional associ-ations and through the Council. If you look at the membership ofthe Council board, if you look at the membership of the MiddleStates Commission on Higher Education Institutions, I think youwill find heavy representation from major institutions.

Mr. PELTASON. If' I may say, Mr. Chairman, it is not as heavy asit should be, but it is getting better. That is, our national commis-sion made the same point, the Association of Governing Boards'publication, and it is now getting established that if you want tomake the case that the community has to regulate itself, then thatis the professional responsibility of everybody including the mostdistinguished and most experienced.

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Mr. K000vsF.x. Thank you, Mr. Chairman.Mr. SIMON. Mr. Packard.Mr. PACKARD. Thank you, Mr. Chairman. I have just one ques-

tion.You based a good deal of your concern on the premise that there

have been abuses through the Department. Could not those sameabuses also exist in a self-regulated program? Where is the tie-inwith your proposal with a self-policing system of your Council tothe Federal Government or to the Department of Education?

Is there any tie-in back to the Department in terms of regula-tions that this Council would have to follow?

Mr. BOYER. Yes, thank you. The first' point I want to make isthat the Secretary, and prior to that the Commissioner, for a longtime has already, delegated to a volunteer body. He does not go tothe campus, he trusts the regionals. So we already once are re-moved.

I think it is not stretching it too much to say that now there isan interagency voluntary accrediting body, the Council on Postsec-ondary Atcreditation, and that body might become increasingly thevehicle by which the Secretary carries out his legal mandate ofoversight.

Now the question is, and you are asking, what might be thetissue that would connect here? We do not speak to that in ourreport and I think it is absolutely the nub question.

I should think it would be possible to establish perhaps a public/private panel that would allow both the Office of the Secretary andthe Council to work collaboratively in developing criteria, and thenhave periodic oversight at the Federal level to see th.9 extent towhich the process is functioning, but stop short of having the Sec-retary, in effect, become involved in the step-by-step arrangement.

Now to some extent, that does perhaps still keep the Departmentclose in but I think stops short of the arrangement now, which ac-cording to the Secretary's testimony, involves the Federal agencyin recognizing what he says are "the 77 components, 47 organiza-tions, including 13 commissions, 64 other bodies."

It just seems to me that we do not have the machinery to do it,the wisdom to do it, and when it is all over, it does not achieve theend that was intended.

Coming back to the other arrangement, we are asking in ourreport, and maybe this is the broader response to your question,are we at a point in governance, a very unhappy word, where, infact, we need to think of some public/private mechanisms more for-mally organized in which we can negotiate issues hi which publicinterest and private effort are to be carried out?

I think that we need to think more carefully of that. Other coun-tries feel a bit more comfortable with a public/private engagement.I think we have seen this so brittly, it is either/or. I do not believethat is true here. As Secretary Bell said, this is a point where twointerests are engaged. How can we have public oversight with,maximum private effort?

As an example, in our report we suggest that perhaps the timehas conic for the National Academy of Sciences to join with theFederal Government in a standing oversight hearing on tension

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points regarding research, such as DNA, such as use of human sub-jects.

Can we establish what already goes on, on an ad hoc basis, giveit some kind of credibility? I think it would be possible to create akind of ongoing forum in which the public accountability and theprivate machinery could negotiate the ground rules with credibil-ity, and we would keep testing that experiment.

But I do think, Mr. Chairman, it is in a sense the essential ques-tion at the practical level.

Mr. PELTASON. Could I just comment very briefly. I think wehave to again distinguish between determining which institutionsought to be accredited and which ought to be eligible for Federal efunds.

The Secretary has the responsibility of doing that, and there is adifference between a prior decision and then policing it. Any insti-tution that is not collecting the loans or violating any law or cheat-ing on the funds ought to be investigated and the Secretary cannever give up that responsibility for seeing to it that Federal fundsare honestly, constitutionally, and legally spent.

That is a separable question from "Is that an accredited institu-tion?"

Mr. MILLARD. And even from general eligibility.:.dr. SIMON. Mr. Owens.Mr. OWENS. I would like to clarify one basic point. Are you

saying that if an institution is accredited, it is automatically eligi-ble or does the Federal Government have its own additional supple-mental assessment and evaluation?

Mr. MILLARD. Given the current law, there are three conditionsof eligibility. One is that the institution must be authorized to oper-ate or chartered in the State in which it exists. The second is thatit must be accredited by a recognized accrediting agency, one onthe Commissioner's list or there is the three-letter alternative.

The third one is that it must meet the specific conditions of theparticular program from which it is receiving funds. This doesbring the Federal Government back in and I think in a very legiti-mate and important way.

Mr. OWENS. Does the Federal Government, on that third point,always make its own supplemental assessment and evaluation of aschool, or does it rely on accreditation?

Mr. MILLARD. Dick Rowe, I think, could answer this more effec-tively than I, but as I understand the way this situation works, youattest to the accredited status of the institution and then the spe-cific eligibility is established in light of the unique characteristicsof the law in question.

This is done by a unit within Mr. Rowe's office.Mr. BOYER. Could we put it this way, there is no way to become

eligible for Federal funds without being accredited by one of theagencies on the approved list. A given program may have specificregulations regarding that program which have to be met, but theprior requirement is that you be accredited.

Mr. OWENS. My question is, How automatic is the eligibility anddoes the Federal Government or the agency of the unit responsibleconduct its own separate assessment and evaluation as to whetheror not those two points that you mentioned before can be met-

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fiscal accountability and personnel administration to meet the re-quirements of affirmative action?

Mr. BOYER. No.Mr. OWENS. They do not.Mr. BOYER. The agency, as I understand your question, the Gov-

ernment does not inquire, it simply trusts that if you are accred-ited, you are a legitimate institution that is obeying the law, youcan manage ,.our affairs, and you will not be unfair, and all thethings that Government agencies care about.

Mr. MILLARD. With one exception. As far as the student aid pro-gram is concerned, it is followed up by a specific audit of the stu-dent aid activities of the institution, which is done by the FederalGovernment.

Mr. OWNS. Is there anything which prohibits the Federal Gov-ernment in its process of certifying or accrediting the accreditors torequire that they have a strong component which looks at thosetwo primary considerations that the Federal Government is con-cerned with, affirmative action and fiscal accountability?

Mr. BOYER. Mr. Owens, that is where, in my judgment, we have abig problem. When I was commissioner and I started to inquireinto criteria, I felt they were very soft and mushy, and they gaveme no assurance, having gone through the elaborate procedure,that the institutions that were accredited by that body would meetthe two things I cared about, can they manage the money, and arethey going to meet equal opportunity and fair practices.

We were not requiring that in a clear and explicit way of the ac-crediting bodies, and although I think it has improved, Dick, Iagree with you, for a long time even those were not investigatedwith care by those we were frankly empowering.

Mr. OWENS. There was nothing in the law which prohibited youfrom requiring that, was there?

Mr. BOYER. That is precisely right.Mr. PELTASON. The law assumes that an institution that is

accredited is complying with the law.Mr. SIMON. Mr. Gunderson.Mr. GUNDERSON. Mr. Chairman, in light of the time, just one

quick question to Dr. Boyer.In your testimony on page 6, you make the following statement:Looking ahead, tensions among departments and disciplines may increase as

budgets tighten. In such a climate, professionals on campus may be even moretempted to abuse accreditation using the process not to protect the public and pro-mote excellence, but to gain leverage in the competition for dollars.

In your study, is there any indication that that exists today.Mr. BOYER. Yes; indeed so. I must say, just for the record, we did

not make an institution-by-institution survey. We did sample insti-tutions by call and conversation to get a sense of what was goingon, and there was no uestion, although we did not have a longitu-dinal study, that on any campuses, with cutbacks in budget, de-partments and sch is within the universities were organizingthemselves like pulliqg the wagons into a circle.

Very often they were defending their own budgets around theclaim that we will lwe our accreditation, or accreditation is beingthreatened. I do not want to say that all of that was wolf, but I amsaying that there was a lot of evidence that accreditation increas-

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ingly is being used for pockets within an institution to establishleverage.

I am just concerned that the Federal Government, even unwit-tingly, not be drawn into what I think will be increasingly a profes-sional matter perhaps of high tension.

Mr. PELTASON. Most college presidents would endorse that state-ment.

Mr. MILLARD. Could I make just one comment. You would haveto be awfully careful, however, of something else. This may well betrue under some circumstances, but we are moving into a period ofextraordinarily tight funds. It may well be the case that there aresome institutions that have programs that they should not be offer-ing at the present time because they do not have the adequatefiscal resources to carry these out.

One of the functions which the specialized accrediting associ-ations do perform is ringing the danger signal when this is thecase. If, for example, you have a law school and you do not haveadequate funding to allow it to operate effectively, there is a realquestion as to whether you ought to have a law school and theremay well be a case in which the accrediting agency is one thatsounds the warning that this is a time when you really ought totake a look at whether you should have it or not.

Mr. SIMON. We thank the three of you very, very much for beinghere.

Mr. BOYER. Just for the record, I think, Mr. Chaifman, I said"podiatrist" instead of "chiropractors," and I believe that it wasthat organization that caused me problems.

Thank you very much.Mr. SIMON. Thank you.[Whereupon, at 11:31 a.m,, the subcommittee was adjourned, to

reconvene subject to the call of the Chair.)

54

HEARINGS ON INSTITUTIONAL, ACCREDITATION

THURSDAY, FEBRUARY 10, 1983

I'. E OF REPRESENTATIVES,SUBCOMMITTEE ." POSTSECONDARY EDUCATION,

COMMITTEE ON EDUCATION AND LABOR,Washington, D.C.

The subcommittee met, pursuant to call, at 9:40 a.m. in room2261, Rayburn House Office Building, Hon. Paul Simon (chairmanof the subcommittee) presiding.

Members present: Representatives Simon, Harrison, Colemanand Petri.

Staff present: William A. Blakey, counsel; Mary ln L. McAdam,legislative assistant; Betsy Brand, minority legislative associate;and John Dean, assistant minority counsel.

Mr. SIMON. The Subcommittee fm Postsecondary Education willcome to order. I will simply enter my statement in the record.

[Opening statement of Chairman Simon follows:]OPENING STATEMENT OF HON. PAUL SIMON, A REPRFSENTATIVE IN CONGRESS FsoM

THE STATE- OF ILLINOIS AND CHAIRMAN, SUBCOMMITTEE ON POSTSECONDARY EDUCA-TION

The Subcommittee on Postsecondary Education today continues its hearing on thesubject of institutional accreditation. These hearings are intended to focus the Sub-committee's attention on the accreditation process, the access to and management ofFederal funds (especially Title IV student assistance), and the proper role of theFederal Government in the determination of institutional accreditation.

Tuesday's witnesses provided their enlightened opinions and an important body offactual information regarding the determination of institutional accreditation underpresent law, the shortcomings of the Department of Education's present proceduresand how that process might be improvedwithout sacrificing institutional auton-omy and assuring proper management of Federal student aid funds.

Today's distinguished witnesses should provide another perspective on the issueshighlighted in The Carnegie Foundation Report "The Control of the CampusAReport on the Governance of Higher Education". The Subcommittee is pleased towelcome Commissioner Gordon Ambach from New York, and representatives of theSouthern and North Central regional accrediting associations, and the Associationof Independent Colleges and Schoolswhich together are responsible for accreditingthe largest number of colleges, universities and proprietary institutions in America.I want to emphasize that our hearings have no specific legislative purpose. We arehere to learn and I am sure we will.

I invite any accrediting associations that did not have the opportunity to presentoral testimony to submit their views for the record. I want to include in the recordat the conclusion of today's testimony an article by the Dean of the School of Tech-nical Careers at Southern Illinois University entitled "Training, Retraining andContinued Professional Education for Adults". Dean Miller's article raises the pros-pect of the expanding number of technical career fields and the likelihood thatmore, rather than fewer, areas of specialized accreditation Well be forthcoming.

Mr. SIMON. We are taking a look at accreditation No. 1, to see ifit is a problem, and No. 2, to see if there are some modifications,

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either in the statutes or in the adminiitrative procedure thatshould be looked at.

It is, I think, safe to say that the Carnegie Foundation report, to-gether with a few other things, have precipitated these hearings.We are pleased to have as our first witness the Honorable GordonM. Ambach, the president of the University of the State of NewYork and the commissioner of education for the State 'Of New York,

Mr. AMBACH. Good morning, sir.Mr. SIMON. Good morning. We aie pleased to have you. Let me

apologize to you or to any other witness that may be on in another20 minutes while I duck out just very briefly to another meetingwhere I have to make an appearance. I will be back, but now willturn over the chair to my colleague.

Pleased to have you here as a witness and look forward to homewisdom now.

STATEMENT OF GORDON M..AMBACII, PRESIDENT, UNIVERSITYOF THE STATE (IF NEW YORK AND COMMISSIONER OF EDUCA-TION, STATE OF NEW YORK

Mr. AMBACH. Thank you very much, Congressman Siinon.I am Gordon Ambach, president of the University of the State of

New York and commissioner of education for the State of NewYork. I appreciate very much the opportunity to be with you thismorning. I have a statement which I have filed with the subcom-mittee.

Mr. SIMON. It will be entered in the record.Mr. AMBACH. I would like to summarize that statement, making

the pertinent points with respect to a State's experience in accredi-tation. The first portion of the testimony outlines a bit of the histo-ry of our State's role in accreditation. The second part somethingof the procedures that we use. Third, I would like to comment spe-cifically on some of the recommendations in the Carnegie Founda-tion report, and then a very brief summary of why we expect tocontinue in the business of accreditation in the State of New York.

Responsibility for providing and supervising education, of course,is essentially a State and local responsibility. The board of regentsof the University of the State of New York has been charged, since1784 with the responsibility of governance of all of education inNew York State, that is, governance with respect to postsecondary

institutions over all of the public, the independent and the propri-etary institutions.

We have been an accrediting agency since 1784, with almost 199years of experience in chartering educational institutions and ap-proving academic programs. The regents have been recognized asan accrediting agency by the U.S. Office of Education and then sub-sequently by the Office of Education since 1952, the first time inwhich such accreditation was recognized by that Office.

Under our law, the regents and then the education department,has a specific function for program review, academic programreview, and for the planning of education in our State. Very cen-tral to that responsibility, of course, is our concern for the excel-lence of the system in New York State.

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STANDARD REFERENCE MATERIAL 1010a(ANSI and ISO TEST CHART No 2)

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Under our procedures, we, in fact, accredit programs. There aresome 15,000 registered programs, each .of which leads to a specificauthorized degree, which have been registered frOm 250 differentdegree-granting institutions in our State.

There are approximately 500 new requests for programs eachyear, which gives you an idea of the pace at which we must contin-ue a very current review process.' We do undertake our reviewswith standards which are established by the department and ap-proved by the board of regenti. We do have site' visits when thereis a substantial change in program direction, otherwise it is areview on the representations made by the institutions, and we usea peer review process, both from peers of faculty members withinour State and outside of the State.

In order to establish our standards, we seek the advice of the col-lege and university presidents within our State and I might notethat within the past 2 years, we have an extensive review and thena concurrence or approval of our institutional chief executive offi-cers on those standards.

Approximately every 5 years, we conduct an institutional visitfor each of the degree-granting institutions. It is more frequent ifthere is a particular problem, but it is essentially a 5-year time-frame. -

When we do a site visit, we do, of course, concentrate on the pro;grams which have begun since the last site visit. We are in very ,close coordination with the Middle States in our accrediting processand also with specialized accrediting organizations where they maybe reviewing programs of the institutions within our State.

We have a very strong relationship with the Middle States Asso-ciation in this process, but we cannot rely solely on the MiddleStates Association, nor the specialized accrediting agencies, forthese reasons. Generally speaking, their visits are at a 10-yeartimeframe and we have, as I noted, approximately a 5-year time-frame for ours. We must review more often and we have a veryparticular concern about reviewing new program starts even beforethey begin. That is, of course, not a part of the Middle States Asso-ciation process.

We have a very strong need, second, for control on our academicprograms because eligibility for various ,State assistance programs,both student and institutional, is based upon that accreditation andreview process by our department.

Third, we are very much concerned about the intersector be-tween the secondary and the postsecondary institutions and thecontrols with respect to both by way of articulation, by way of dif-ferent program responsibilities.

Fourth, I would note that regional accreditation is, of course, avoluntary process and our concern is that each an every institu-tion in our State, whether they would volunteer for such an ac-creditation or not, is provided with this thorough program review.

And fifth, I would note that we have a 'particular concern withthe review of programs where there might be an attempt by anout-of-State institution to offer a program within our State. Wehave very tight controls on that and have prevented diploma millsfrom operating at all within the State of New York.

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May I turn now quickly to the recommendations of the CarnegieFoundation report. I note that of the six recommendations that spe-cifically address the State role, we are in strong concurrence withthe first five of them. That includes the planning and providing ofbasic support-Tor the comprehensive system of higher education,encouraging good management by permitting administrative deci-sions to be made close to the locus of implementation, creatingbroad categories of expenditures, fostering close relationships withregional accreditors, and promoting diversity.

I have noted in my statement specific ways in which we aretaking actions which I think demonstrate our commitment to thoserecommendations.

I do want to emphasize that in our role, we do not review thebudgets of the public institutions, nor, indeed, of independent insti-tutions in our State. There is not a commingling of budget reviewand program quality review.

We do oppose one of the recommendations in the Carnegie Foun-dation report, that is at page 81, and it has to do with the matterof State activity on academic program review. The recommendationreads: "State officials should not involve themselves directly in thereview of academic programs," and that recommendation, ofcourse, is based on an expression- earlier in the report about pre,serving, and I quote, "four essential freedoms of a university to de-termine for itself on academic grounds who may teach, what maybe taught, how it shall be taught, and who may be admitted tostudy."

As I have described earlier, our department reviews of academicprograms provide an assurance of State standards of quality. We donot, however, define course or program content or determine whoshall be faculty members and how they shall teach. Nor do. wemake admissions policies or decisions.

We are very conscious about the delicate balance between adam,demic freedom and institutional prerogative and the public inter-est.

As I noted, our responsibility is to review individual programs.We have a particular interest in controlling new starts, new pro-grams advanced by the institutions. I think that is an extremelyuseful function, not only for our State, but for the institutions, be-cause it assures that they have carefully thought through exactlywhat new directidns they are going to take.

I would also note that by having a review on a program-by-pro-gram basis, it means that if we should find some defect, we candeal with it specifically on that program and not on the institutionas a whole. The task of providing sanctions which deal with entireinstitutions is a much more diffictilt and in many cases more cum-bersome one, than to deal with specific program offerings.

I have made the point before, but I repeat, the importance of ourrevittws by way of our concern for aid eligibility, both student andinsthutional, in our State, our' student assistance program, which iscalled the tuition assistance program, exceeds $300 million of Statefunds per year. We have a very great stake in that program andthe eligibility of 'students to receive that, as well as for the Federalfunds.

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We have substantial institutional aids for both the independentsector and of course from the State budget for our State universityand the city university. Once again, to assure the public interestwith respect to these expenditures, this program control andreview is extremely important.

There are two other regomMendations in the Carnegie Founda-tion report which I waht td indicate we.would oppose, ot we wouldsuggest some modifications. Th.ase appear at pages .83 and 84.

The first has to do with a statement about the agencies whichshould be recognized by the Secretary of Education as accreditingagencies. The recommendation reads, and I quote: "In determiningthe eligibility of colleges to participate in Federal programs, theSecretary of Education should use regional accreditations. as thebasis for approval."

I would respectfully submit that on the basis of our experienceand acknowledging that it is a unique experience, Mere is no otherState that has quite the same role, the statement really should be"The Secretary of Education should use regional. and appropriateState accreditation as the basis for approval."

The following recommendation, then, in the report is, "The prep-aration of an approved list of regional associations should be afunction of the Council of Postsecondary Accreditation', not theFederal GovernMent." I respectfully oppose that as well.

I believe that the function has been given to the Secretary be-, cause there is a very, very great public interest and I 'believe that

the function should continue to remain with the Office.of the Sec-. retary.In conclusion, may I note that on the experience, which again I

emphasize is a unique one, of nearly 200 years of chartering, ofprogram review, I believe that we have established a very strongcase for an effective role in a State for an accrediting function by aState agency. I do submit that as you are deliberating on this issue,perhaps considering any changes in Federal statute with respect tothe powers, that that role of a particular State be considered.

Indeed I would go a bit beyond that. Very intricate arrange-ments, as among the Federal level, the accrediting associations, re-gional or speciality, and the States, is an extremely important bal-ance that must be maintained. I would submit that perhaps the ex-perience of New York, where we have a certain division of thoseresponsibilities, is one that might be considered as something of amodel for other parts of the country.

Thank you very kindly for the opportunity to testify.[The prepared statement of Gordon Ambach follows:]

96,PREPARED STATEMENT OF GORDON M.*AMBACH, PRESIDENT, THE UNIVERSITY OF THE

STATE OF NEW YORK, AND COMMISSIONER OF EDUCATION

I am Gordon M. Arnbach, President of the Uniersity of the State of New

York and Commissioner of Education New Yoi.k State Education Department.

I welcome this opportunity to present testimony on institutional accredita-

tion. The first portion of my testimony outlines the history and framework of

accreditation iriNew,York State. The second section outlines the procedures and

standards that are erpleyed in New York. The third section addresses the

recommendations of the Carnegie Foundation report, "The Control of the Campus.-

A Report of the Governance of .Higher Education" that pertain to State agencies.

In a brief conclusion I will summarize why New York has retained responsibility for

accreditation and plans to contirme in that role.

Background and History

Responsibility for providing and supervising education has resided consti-

tutionally) and traditionally with the states and their local jurisdictions. The

statute that created the Wilted States Department cg Education states: "The

establishment of the Department of Education shall not increase the authority of

the Federal government over education or diminish the responsibility for education

which is reserved to the States and the local school systems and other instrumen-

talities of the States."

The Board of Regents is responsible for education in New York. The Board

was created by an act of the New York State Legislature in 1784 which invested

the Board as governing body of the University of the State of New York. This

University includes all educational institutions in New York and has a clear

legislative- mandate to supervise all education in the State through the State .

Education Department. Responsibility is authorized by the Ne% York State

Constitution and set forth explicitly in Education Law. The fit teen Regents of the

Board ,cire elected to overlapping, seven-year terms by action of the New ,York

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State Legislature. One member of the Board is from each of the State's eleven

judicial districts arid four are elected at large. They appoint the Commissioner of

Education who, in turn, appoints staff. The programs and operations of the State

Educatitn Department are financed by.approPriations in the State and Federal

budgets. This system of governance.and oversight is unique and is oriented solely

to the public interest for the qualip of education in New York.

The Board of Regents has been an accrediting agency since its inception in

A 1784 and for 199 years has been responsible for chartering educational institutions

and approving academic programs. The Regents have been recognized as an

accrediting agency by the United States Department of Education and previouslyA

by the United States Office of Education since 1952 when such recognition was

first available. This recognition is based upon meview of the Regents policies and

procedures for accreditation in relation to criteria of eligibility.

New York Education Law requires the Board of Regents, and the Education

Department as its executive arm, to accredit all degree-granting institutions in the

State. In addition, the Education Litw re4Uires the Regents to prepare a

quadrennial Statewide Plan for Postsecondary Education, based upon the individual

master plans of all degree-granting instjtutions--public, indepen%dent, and proprie-

tary. The plan establishes the comprehensive framework for higher education in

New York. This combination of responsibilities for plvaming and program review

enables the Regents and Education Department to plan for excellence with the full

involveinent of all colleges and universities. Indeed, the 1980 Statewide Plan and

the proposed 1984 Plan have as one of four principal goals the achievement of. -

academic excellence. We are collaborating with the institutions to accomplish

such objectives as: improving graduation rates without diluting standards; improv-

ing graduates' records of relevant job placement and admission to more advanced

levels of study; enhancing library collections for instruction and research;

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preserving the role of the liberal arts and science's; expanding study of other

languages and cultures; and fostering cooperation among schools, businesses and

college, to enhance the attractiveness and effectiveness of teaching in the

elementary and secondary schools. Our pursuit of these aims, as well as 'our

consideration of individual program proposals, would be weakened materially by t4,e

absence of one of the complementary roles of academic revieN and planning.

In summary, there is a long, unbroken and clear history of comprehensive

responsibility for postskondary education being vested in the Board of Regents and

State Education Department in New York for almost two centuries.

Accreditation Procedures

The accreditation activities of the Regents and State Education Department

focus on academic programs. There are some 15,000 registered programs (each

program leads to an ,authorized degree) In nearly 250 degree-granting post-

secondary institutions in New York. Approximately 500 new programs are proposed

by the State's public, ind? pendent and pre prietary institutions each year.

The standards for registration of programs are set forth in rules andti

regulations adopted by the Regents and have the force and effect of law. Proposed

programs are evaluated against the standards by Department staff and by expert.

consultants drawn from colleges and universities in and outside New York. In those

instances where an institution proposes a prograra that represents a significant new

undertaking (for example, its first program in business or a new law school) the

proposal review by staff and consultants is supplemented by, a site visit to ascertain

commitment, plans and the adequacy of resource. In those cases we also conduct

a planning review that permits other institution to register their views on the need

for and likely effects of the proposed,progr am.

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The standards of quality bear on faculty, curriculum administrative support,

student serivices, land resources including classrooms, library collection and space,

laboratolies, equipment and an adequate financial base. They are put in general

terms to permit variety, flexibility and contemporary peer judgment. Thciie

general standards are reviewed and revised periodically by the Board of itegents

following consultation 'with a council of two dozed college presidents, who adivse

my, staff and me on a' variety of matters. 'affecting higher. education. Moreover,

there are provisions toswaive these general requirements, if an instituion wishes to

propose a particularly innovatiVe program.

If staff and consultants have questions or concerns about some element(s) of

a proposal in relation to the standards,, the proposing institution has ample

opportdnity to .clarify and explain as well as to suppleMent. The essence of the

review. process, theretore, is to ensure equality without thwarting creativity; to

preserve academic f(eedom while protecting.the interest of studenis, their parents

and dmployers, and the public.I

Approximately every five. years the Departrqent conducts a visit to eachI I

degree-granting institution following a'self-evalution by the college or university..). ...-

The visiting team usually consists of one -or two staff member and frot,n two to six

consultants from the academic community who are selected or their knowledge of

particular fields to be reviewed and with careful attention to experience that is.,,\pertinent .to;the type and level of instituion to be visited. The college has the

opportunity to object. to any of the proposed visitors. Here again, the generalt

standards contained in rules and regulations provide the legal framework within

which peer judgments are made. The site visits enable "the evaluation of .the

institution's overall health but, in addition, permit special examination of such

matters as off-campus instruction and t:ernedial education--both of which have

grown dramatically in recent years - -and programs that were instituted since the

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last visit and which were not evaluated on site when first proposed. Staff provides

a draft site visit report to the college president for comments and, corrections of

fact, before a final report is made. In additiOn, there. are due process safeguards

for the institution if a program is found wanting.

Such accreditation or registration visits are coordinate with the visits of the

regional_ accrediting bqdy, the Middle States Association,, and with those of

specialized accrediting organizations wherever possible, in order' to reduce the

. -burdens upon the institutions and to capitalite on 'the competence of the teams

assembled by other accrediting bodies.

Our coordination with the Middle States Association~ is efficient and

economical and our relationship with Middle States in this process is excellent. (in

fact, the Middle States Association was chartered by the Board of Regents..,

Nonetheless,, all of our needs cannot be met nor all of our responsibilities

discharged by relying, on their accreditation activities. Barring significant

problems, visits by the regional associations are scheduled at ten year intervals.

Although periodic reporting requirements may be employed, the visits are too

infrequent for our Department to be confident that changing institutional

circumstances,in such areas as leadership, financial strength, nature and size of

enrollments and locations of instration have not altered significantly the,quality.

of a college or university's 'offerings. Several colleges have propoSed first.baccalaureate or graduate degree programs, new piofessional schools and new

branch campuses in just the past few months in New York. The Regents and

Department cannot wait years before conducting an appropriately seaittching review

of such proposed initiatives. .;

New York State has an extensive set of State programt of financial

assistance to pos..secondary institutions and students (perhapi, the most extensive

array in the nation).. The confidence of the Governor, State Legislature and public

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in New York of.the valiie of these aid programs is based in law part on the qualityIP*

control of the reviews and 'accreditation we conduct to establish institutional

eligibility.

The Board of Regents and Education Deoditment also have responsibility for

all public and non-public elementary and.secondary education in New York. At thistime when there is .conilder able experimentation on the rpost el !active dividing

points and relationships between the postsecondary and secondary institutions, it is211 especially important to maintain an effective control of program quality for both

r,

sectors at out State level.

g, It must also be borne in mild that regional accreditation is voluntary: not all

institutions in Nom York have or seek it including an institution such as Rockefellero

University. Without the accreditation of the Regents, this nationally, prestigious

institution would be ineligible for Federal aid.

One other most valuable attribute -of our accreditation role is the ability to

regulateout-of-State institutions that seek to offer instruction for college creditin New. York. The Depariment's statute-based activities and control of this areak

have prevented diploma mills from operating in New York.

Carneaisaezt:tecoRecommendations

The Carnegie Foundation report, The Control of the Campus, makes six

recommendations with respect to state activities in higher eduCation (page 81) and

two related recommendations on accreditation (pages 83-84). We endorse five ofthe first set of recommendations, those relating to planning and providing basic

support for a comprehensive system of higher education; encouraging good

management by permitting administrative decisions to be made close to"the locus of

implementation; creating broad categories of expenditures; fostering close relation-shi pi with regional accrecli tors; and promoting diversity, The Board of Pegents and

rti

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102

State Education Department have taken many steps to promote diversity, nurture a

comprehensive system of postsecondary education and develop close tics to the

middle states, Association. We have also ecouragbd the maximum degree of

management flexibility for our colleges and universities that is consistent with

protection of the public interest. Our most recent statement' en this issue,

included in our bulletin calling for the 1984 Statewide Plan for Postsecondary

Education, has this obserationi

Continuing economic austerity and rapidly shifting academic goals have

Combined to create a requirement for greater management flexibility in

our public and independent institutions of higher education. In the,

acade,mic area,.the need is for, more freedom from undue constraints

from governmental and voluntary accrediting authorities, without

abandoning the goals of quality and responsible performance those

conttaints were intended to protect. In the fiscal area, the need is to

, permit flexible use of government funds in a period of scarce resources

while preserving accountability and responsiveness to the intent of the

(State) Legislature, the. Governor, and/or the Congress in allocating

public funds.

I want to emphasize that the Regents and Education Department do not

review, the budgets cif public colleges and universities as do higher educatiA,

agencies in many other states nor, of course, do we review the budgets of

independent institutions. There is 5no commingling of budgetary and program

review resgonsibilities by our agency,.

We oppose one rec:ornme-nclation in tLess )911lotinpe 81) bearing on state11mIMI

ar..tivity.because it is contrary to our exi)crience and'practice. The recommencia.

tion reads, in par,t: "State officials should not involve themselves directly in the

review of academic programs." The report recommendation is based on a concern

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expressed earlier in the report about the preservation of "the four essential

freedoms of a university: to determine for itself on academic grounds who may

teach, what may be taught, how it shall be taught, and who may be admitted to

study." (Sweeny v. New Hampshire)

As described evolier, the New .York State Education Department reviews

academic programs to ensure adherence to State standards of quality. We do not,

however, define course or program content, or determine who shall be faculty

members and how they shall teach. Nor do we make admissions policies or

decisions. We are very conscious of the important and delicate balance between

public'Interest and academic freedom. We believe that the State Education

Department role in academic review has not compromised academic freedom in the

institutions While it has promoted quality. One of the areas of most rigorous

review has been our ten year project of reviewing' noctoral programs, field by

field. This has been done with strong institutional support. New York institutions

have not been impeded in operalien because of such reviews as may be seen by the

results of the reputational study of doctoral program quality conducted by thea

Cent erence [Ward of Associated Research Councils.

The Regents and Department review individual programs rather than accredit

overall institutions. This apprbach enables consideration of proposed new' programs

before students are admitted. While some institutions conduct searching reviews

before starting programs and of ten engage outside consultants, others do not.

Institutions sometime respond too quickly to perceived comPetitive pressures from

neighboring institutions without providing the planning and resources that will yield

a sound program. An objective review in advance of a program can avoid many

subsequent problems for students, faculty and others.t.

A second advantage of program-by-program review is the ability to focus on

pacts of ,an institution's offerings, and either require change or deletion of a

program without jeopardizing the entire institution.

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A third reason for review of individual programs pertains to the $300 million

Tuition Assistance Program (TAP) and other student and institutional aids offered

by New York. TAP'is by far the largest-program of State-funded student aid for

'Higher education in the nation. By State law, student eligibility relates in part to

enrollment in a proigram as registered by our Department, not merely in an

'accredited institution.

In summary, the State review of programs has provided a carefully focused

control without intervention in institution choices of faculty or courses.

We oppose also two of the recommendations on Federal action with respect

to accreditation (pages 83-84)..4*w

For the reasons just provided in support of our State accrediting responsi-

bility, we oppose the limit In the following recommendation: In determining the

' eligibility of colleges to participate in federation programs, the Secretary of,

Education should use regional accreditations as the basis for approval." The

recommendation should read "...The Secretary of EducatiOn should use regional and

appropriate State accreditation as the basis for approval."

The next recommendation of the report: 'The preparation of an approved list

of regional associations should be a function of the Council of Postsecondary

Accieditation, not th6 `federal government" is opposed also. We find no logic in

removing this responsibility from the Secretary who must, in turn, assure the

Congress, President and public interest of a prudent expenditure of billions of

dollars in government aid. The Secretary's power to establish determination of the6.4

list of accrediting agencies should not be reassigned.

6

Conclusion

In the letter of invitation to tstify, Congressman Simon asked why New Yorkz

has retained the responsibility to accredit its colleges and universities. As thedt.

108.

7--foregoi.ng.testimeny indicates, these is_a_nearly;.,200.year4histoty-joLresponSibility

for7actreditAleh_assigried :by,doristi`tutiop and statute 'to the Board of Regents and'_5:_:,the.:State:EduCation Department. The exercise- Of that responsibility is made

possible-r-bY Million . of State lunds:apprOpri ated-ishriuil I yEby-

listpre upon recommendation otthe..covernor fpn:P.0:114-t.-0:Progrant--accredtation.,.v,..

This-COMini.foient of reieurdeS is, rooted in the belief ; -that

6..ess,prance.oteducational.quality-M all of New Yorks colleges and universities-:-

public, independent: ancl,,.Pro.Priet4r1;"4;:alegitimsto-..right and,responsibility of -the

StAteggY..gtrirnes_t1 irt.o.tder Ao...protett_ltudents..ind -those, who -have an

their teceivi ng_.a, sound ediicati Thetiatter- liiclOdes :the general pylic..which.,-,

supp9rt programs of students and_innitutional aid,an0.,.r.ietka capable. and well-

edtiCat&d, Ci ti 'Ont.)? ,,.tO :tosters.econOmic growth and. to prOrnote social and. -civic

...,:attierlstates_rnay-be.,:unable-or-unwilling to-commit-the -effort 'and .resourCes

to accreditation. New York has the benefit of tradition and experience and a

broadly shared commitment to a quality,of education which is_to be maintained ink

all institutions through the oversight of State agencies. ,_ We arercertairirths_.,,,,,f,corornitrnent will continue, and we urge that the Congress and Federal administra- '

tion support this State practice and take no action which might disrupt itseffectiveness.

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Mr. SIMON. Thank you. You are hem; wearing two hats, so tospeak. If I can ask you to put on your hat as president of the Uni-versity of the State of New York, do you find the present accredita-tion process islet me specifically cite Gpmmissioner I3oyer's experience in your State in which he said thIt one of the accrediting'agencies accredited by the national associations, I, forget which oneit was, came to him and he had rejected having two associate deansbecause it looked like in that school one associate dean was plenty.They came to him and said, if you do not have two associate deans,you are going to lose your accreditation with the national, what-ever it was, association.

Mr. AMAMI. That was probably a specialty review, then, otherthan the regional.

Mr. SIMON. Yes, that is correct.Now, is this a problem that you have confronted and is there any

sense in the Federal Governr4nt accrediting the journalism groupor some of the more specialized accrediting groups like the businessschools association? I am not `talking about the proprietary schoolbecause it seems to me there are these broad, general 'categorieswhere clearly we have to be involved. But the journalism schoolsand that sort of thing, I would be interested in your comments andreflections.

Mr. AMBACH. May I speak specifically, of course, about our role,and you are asking about a dual role. Perhaps it sounds like a dualrole, the president of a university and Commissioner of Education.It is, in fact, one and the same role. The two titles have to do withthe fact that all institutions in our State are a part of the Universi-ty of the State of New York by their charters. We do not directlyoperate them, but they are a part of that.

That is where the presidency title comes from. The commissionertitle is as the chief executive officer of the education department inour State with responsibility for all levels.

Mr. SIMON. That includes, just so I understand, that you are intheory the head of Fordham University in the private as well asthe public?

Mr.'"AmaAcii. That is correct. Not the head of Fordhain.Mr. SIMON. I understand.Mr. AMBACH. It has a president, as do all of the other 250 institu-

itns, but in our concept, which again goes back some 200 yearsaand modeled somewhat after the French experience of the universi-ty, there is an all-compassing educational concern and interest thatthe State has. It is expressed in our State in an entity -which wecall the University of the State of New York.

Mr. SIMON. I did not realize that.Mr. AMBACH, I serve as the president of that. And in that sense,

because Fordharn or NYU or Columbia or Syracuse or Rochesterare all parts of the university chartered by us, and in a sense,under the aegis of the board of regents, indeed I am, in a certainrole, responsible for the activities that go on in those institutions.

That power, incidentally, is to such an extent that the board ofregents in the State of New York may remove the board of trusteesof any of those institutions for cause. That gives you a sense of howdeeply this kind of authority is rooted.

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Now, coming back specifically to your concern about the multi-tude of accreditations, or the very specific recommendations thatare made, from time to time there are, of course, disputes as towhat the specificity shall be. I think those tend to occur perhapsmore in the specialty accreditations than they do with the regionalaccred itations.

We attempt to have a very close fit between our own reviews andeither the regional or the specialty accreditations. Of course, we tryto minimize what would be a dispute over an issue which we wouldconsider is not the kind of issue that should be dealt with.

We do not, for example, in our standards, have specific numbersof this or numbers of that. We rely very heavily on peer judgmentand we rely on a general statement with respect to what should bethe appropriate approach to the curriculum, what should be thegeneral offerings, and what should be the quality of the faculty andthe resources.

I thinks hat Your questions lead toward the issue of whetherthere should be some significant change at the Federal level on theSecretary's role here. I would submit that in order that there be anassurance of a level of quality of performance for the expenditureof Federal funds, whether they be in institutional or whether theybe in student assistance form, you must have some kind of a wayin order to have determinations made that there is a consistency ofquality, that there are 'standards to be met throughout the country.

The practice of doing that, since 1952 at any rate, has been amixed role, the Secretary identifies which accrediting agencies,which in turn provide the fields of approval on the institutions thatare eligible. I would submit- that, given our own experience, andwith the inclusiveneys of our experience, that this general pattertof a role and maintaining the Secretary's responsibility, I think ha',.to be there for the Congress and for the public as a whole in thisNation to feel secure in quality control. I think generally speaking,that is a system which works and should continue to work, as Isaid in my opening remarks.

Mr. Si MON. While you endorse five of the six recommendations,fundamentally, when you say this system works, is the systemworking well enough that this subcommittee and this Congressreally need not worry that much about it; or is it that substantialimprovements need to be made?

Mr. AMI3ACH. I am not suggesting that. I am trying to addressthe very specific poiiit which is, I think, the Aivotal point with re-spect to the administelition of Federal progranI would like toemphasize that I am addressing that very, very.pecifically. Youmust have some satisfactory arrangement through which a multi-tude of institutions can be provided with an opportunity to partici-pate in the Federal programs, and yet on the other hand, you havethe assurance that there is a system in place to guarantee a qualityof performance so that-the money is well spent.

Now, that, I think, is one issue. I believe your question now isgoing beyond to the foundation report which, has to do with thestrengthening of the overall accreditation system.

I would make this point with respect to that question. I am notsure that it would be Federal action or that it would be a Federalstatute or provisions coming either through legislation or rules

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08from the Office of the Secretary that would necessarily lead to anymore effective system being in place.

I think the Federal role should be to provide an assurance forwhat is Federal expenditure well guarded. I think that beyondthat, the issue is changing accreditation procedures, and wouldagree with you, there are some significant changes to be made.There are things to tighten up in the system with respect to self-review, with the process of the peer reviews, with an overall com-mitment by the institutions and the lead institution that they areinvolved in their own self-review and the peer review. Indeed,there are things that 'should be changed, but I am not sure thatthose should be changed by way of a Federal action.

Mr. SIMON. Thank you.Mr. Harrison.Mr. HARRISON. Just because the system in New York is so

unique, and I confess that I am not that familiar with it, I haveone question which may seem naive. Do I understand, Doctor, thatit is simply not permissible for an institution to offer a course forcredit in New York that has not been approved by the Universityof .the State of New York?

Mr. AMBACH. That is correct.Mr. HARRISON. And the process by which you give this approval

is your accrediting process, and k S I think you said, you have150,000 courses for credit which are offered in the State-45,000, Iam sorry, take that zero out.

go. Mr. AMBACH. 15,000. The 250 different institutions, public and in-dependent, some propr;qary, together, collectively, now offer15,000 different programs. Each one of those programs leads to aspecific degree. In order for any of those programs to come intobeing, there must be an explicit approval by my agency, that is cor-rect.

This is a very unique system in our country, and _indeed, _oncethose programs are put in place, then our process, of course, is toreview and to assure that there is quality maintained. We havedone that in some very particular ways, one I referred to in thewritten statement but did not comment on here. In the course ofthe last decade, we have had an extensive review of the doctoralprograms offered by the several institutions within our State, field-by-field. So all those institutions, for example, offering a doctoralprogram in history, in economics, have been reviewed from peersfrom outside of the State at one time.

As a result of that process, we have had our institutions in.many

cases actually changing, droppihg certain of their programs, con-solidating them and carrying through, I think very responsibly,with our assistance and with our direction, on assuring that 'wher-ever there is a doctoral program in the State, it meets those veryrigorous standards of quality.

Mr. HARRISON. Is it your concern that if you did not have thiscomprehensive system that you have described that you mighthave a proliferation of what you have called diploma mills?

Mr. AMBACH. That is always possible. The controls, both fromwithin our State and because we have that control on who canbegin in the first instance, we have been able to keep a very tightcontrol on the potential operation of diploma mills from within the

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State. But beyond that, we have a very strong control that any di-ploma mill that may be operating from another State that tries todo business within New York, we can stop immediately, and havein the past done so.

Mr. HARRISON. Very good. I am also glad to know that the Jesu-its are still running Fordbam under your supervision.

Thank you, Mr. Chairman. .

Mr. SIMON. We thank you very, very much, Dr. Ambach, for yourtestimony.

Mr. AMBACH. Thank you ery much.Mr. SIMON. We shall keep it in mind. I will submit questions for

the record, and would appreciate a response.[Information referred to above follows:]

QUESTIONS FOR DR. GORDON AMBACH

1. Since New York is, to my knowledge, the state with the most extensive accredi-tation process, it would appear that other states do not feel that state accreditationis necessary. What impact do you feel it would have if your state no longer accred-ited institutions?

2. During your accreditation and review process do you evaluate the fiscal respon-sibility shown by institutions such as default rates on studerit loans? Do schools everlose accreditation for that reason?

3. Can yoii give us a percentage on how many schools that apply for accreditationreceive it? How many schools lose accreditation during your review process?

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:.11322-141 0-144--8

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THE UNIVERSITY OF THE STATE OF NEW YORKTHE STATE EDUCATION D AUNT

OP/ICE Or THE PRESIDENT OP THE thetveltaarAND COMMISSIONER OP EDUCATION

ALDANt, NEW yallIK ISM

March 10, 1983

Dear Congressman Simon:

I am writing in response to your letter of February 23, 1983, in which youpose several questions concerning the accreditation activities of the New YorkState Board of Regents and its administrative agency, the t'ate educationDepartment. I will respond to the questions in the same order as you listed them.

(1)

You are correct in your understanding that the accreditation process in NewYork State is more extensive than that of other states. That is explained, in part,by the unique history and scope of educational and professional governance that isrepresented by the Board of Regents, as stated in my testimony of February 10.Thee c essittion of accreditation activities by this Department could only impactnegatively on the quality of education in New York State.

Unlike the regional agencies which grant or withdraw accreditation on aninstitutional basis, the Department reviews and accredits individual programs. Asyou may recall from my testimony, this process involves criteria which are notaddressed by the regional agencies. The benefits derived from this, approachinclude the ability to require an institution to correct deficiencies identified duringthe review process or discontinue the programs involved and to assess the qualityof new programs before the institution begins to offer them. An example of thelatter would be a proposal for a °new program in microcomputer informationscience recently submitted by an upstate indepericknt college. Our review of theproposal identified a number of serious deficiencies, including the lack of thenecessary mathematics foundation, inadequate faculty background and training incomputer science, unsatisfactory equipment and library resources, and insufficientfinancial support. Because of these problems the Department recommended that

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the college withdraw the proposal. If the college were located in another' statewithout similar accreditation functions, it would have been able to offer tostudents a seriously deficient academic program which could not have delivered theservices, it promis'd. Inasmuch as the last regional accreditation visit to thatinstitution occurred last year, there woulcl not have been an on-site review of thatprogram until 1997.

Examples could also be cited relating to initial offerings of baccalaureate,master's or doctoral degrees, new professional schools or new branch campuses. Inall such cases, a review in advance is necessary to protect the public. Regional andspecialized accrediting agencie? usually iequire that new institutions be in opera-tion for a period of time before they are evaluated for accreditation. If theseagencies held total responsibility for the accreditation of new institutions, thepeople of .the State and the students enrolled at the institutions would be requiredto wait for a determination as to. the quality of the education beingoffered.

Accreditation by regional and specialized agencies is voluntary. If New Yorkwere to discontinue its process of accrediting institutions and rely instead on otheragencies, there would be no means of ensuring that "degree-mills" were prohibitedfrom operating within our borders. In addition, institutions of quality which lackaccreditation by one of these agencies or choose not to seek it would findthemselves ineligible for Federal aid.

(2)

In response to your second question, the Department is aware of the defaultrates on student loans at each institution because we receive such informationfrom the State's Higher Education Services Cor:oration, the agency responsible forprocessing student loans, grants and scholarships. This issue, however, is 'notaddressed in our accreditation and review process, which is concerned primarilywith academic issues. We would not, therefore, withdraw accreditation on thebasis.of default rates.

Our Department and the hoard of Regents have a significant interest onbehalf of the State. for the financial condition of each degree granting institution.Should an institution have an exceptional default rate or should the default rateimpact on the financial health of an institution, we would review thekirCumstancesand could take action, if appropriate.

(3)

New York State Education Law prohibits any degree-granting institution fromoperating in the State until it has been authorized to do so by the Regents and itsprograms have been registered by the Department. The Department receives alarge number of requests each year for information concerning the requirementsnecessary to establish a new degree-granting institution. Because of the highstandards required of New York State degree-granting institutions, few of theserequests result in a formal proposal for degree powers. of those that do, the"epartment works with the institution in advance of an application to determine, ifthe resources and exoertise exist to offer programs of quality. If it is apparentt'iat the institution will not he able to 'meet repaired standards, it will beadvised to withdraw the proposal without prejudice. We do not keep a formalrecord of applications versus approvals. In the past three years only threeinstitutions received de.lree powers for the first time, Each of these institutionshad been operating for some years as a proprietary business school licensed by thisnepart vent but not authorized to issue degrees.

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With respect to the second portion of that final question, there is seldom aninstance where accreditation is withdrawn from an entire institNion. This, again,is attributable to our practice of registering individual programs. in two instanceswithin the past five years we withdrew accreditation of the entire institution.Both involved highly specialized institutions offering only a few programs. Becausethe deficiencies identified during our review involved all the programs and theinstitutions were not able to submit adequate plans to address these issues, we./required them to discontinue the programs. Iii such instances, the Department'''.works closely with the institutions to ensure that provisions are made to enable,students to complete their studies.

If deficiencies are identified in 'a program during the course of our review,our procedures require that the institution he .given the opportunity to correctthem before accreditation is withdrawn. The institution is asked to submit a planexplaining how each issue will be addressed. If the plan is found to be adequate,the Department will continue the program's registration on a conditional basis.The institution is required to submit periodic progress reports to the Departmentand an additional site visit is conducted to verify that the probleihs have beencorrected.

It is appropriate to note here that the New York State Board of Regents isconducting an evaluation of all doctoral programs in public and private institutionsby major subject area to encourage academic excellence and to ensure a compre-.hensive, high quality system of doctoral education. The procedure for doctoralreview is a unique process which involves peer review, due process, and evenhandedevaluation of all programs from a statewide perspective. The purpose of the

0 Doctoral Project is to identify and maintain programs that meet quality standardsand improve or phase out those that do not. The review process involves out-of-State experts who serve on rating committees and as site visitors and in-Stateleaders in graduate education who serve on the Commissioner's advisory board ondoctoral education. Throughout the review process, institutions have opportunityto respond to findings and recommendations on their doctoral programs. Thiscomprehensive and rigorous review process has identified many programs of highquality. It has also resulted in significant program improvements and' in asubstantial number of program consolidations and voluntary closings where insuf-ficient resources or serious deficiencies were apparent. New York State's strongcommitment to this cooperative review effort ensures that the State's resourcesare being allocated to support doctoral education of high quality.

I hope this information is of assistance to you. If the Subcommittee onPostsecondary Education has any further questions, please feel free to contact me.

Si ly,

o don M. Ambach

The Honorable Paul SimonCtiairmanHouse Subcommittee on Postsecondary Education320 Cannon House Office BuildingWashington, D.C. 20515

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Mr. SIMON. Next we will have a panel composed of Dr. Gordon .Sweetywbo is going to be accompanied by Dr. Whisenton and Dr.Carpenter; 00r. Thurston Manning; alld Dr. James Phillips, ,whowill be accbMpartied by Dr. Robert Kline, and an old, friend, 13111Clohan.

Frank, I am going to turn this over to you.Mr. HARRISON [presiding]. Gentlemen, just let me say that I have

been a part-time teacher in a number of colleges over the years,most recently 'in my own alma mater of Kings College for the 13

o years before they gave me this job, and so I consider it quite anhonor that the first time I get to chair anything around here is'tobe in this particular committee room and. to have in front of ussuch an impressive array of academic talent. Normally, it is the ad-ministrators who are telling the teachers what to do, so I am gladto be on this side of the microphone for a few minutek.

With that in mind, I think we should turn it over to you and askyou to proceed as you think best.

STATEMENT OF GORDON W. SWEET, EXECUTIVE DIRECTOR,'COMMISSION ON COLLEGES OF THE SOUTHERN ASSOCIATIONOF COLLEGES AND SCHOOLS, ACCOMPANIED BY JOFFRE T.WHISENTON, ASSOCIATE EXECUTIVE SECRETARY, COMMIS-SION ON COLLEGES; AND THOMAS CARPENTER, PRESIDENT,MEMPHIS STATE UNIVERSITYMr. SWEET. Thank you. Honorable members of the Subcommittee

on Postsecondary Education, Mr. Chairman, and counsel, I amGordon Sweet, executive director of the Commission on Colleges ofthe Southern Association 'of Colleges and Schools. The Commissionon Colleges accredits degree-granting, postsecondary institutions inthe South and I am pleased to represent our 723 member collegesbefore this committee.

As you already noted, Mr. Chairman, with me are Thomas Car-,penter, chairman of the Commission on Colleges of the SouthernAssocation and president of Memphis State University; and my as-sociate Joffre Whisenton.

Mr. Simon asked that I discuss the role and function of regionalaccreditation and to comment on the recent report of the CarnegieFoundation for the Advancement of Teaching entitled "The Controlof the Campus: A Report on the Governance of Higher Education."

I would like first to offer some general comments concerning re-gional accreditation, then describe how the Commission on Collegpsfunctions in the South, and conclude with reactions to the Carnegiereport. Regional accrediting associations have assigned the task pfaccrediting postsecondary institutions to commissions.

The work of the Regional Accrediting Commission on Postsecon-dary Education has traditionally focused on two important objec-tives: The maintenance of minimum standards of quality in post-secondary education, and the stimulation of institutions to becomemore effective through self-study and examination.'

For the Regional Accrediting Commission on Postsecondary Edu-cation, the work of developing standards and procedures for ac-creditation does not proceed independent of society or the consum-er of educational services. Changes in technology and methods in

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business and the professions create new demands and legitimatepressures for changes in the curricula for our institutions, as wellas in the mode of delivery of educational services.

Changes in the standards and procedures of the Regional Accred-iting ommission are not made capriciously, they are accomplishedonly after intense study and discussion, within the academic com-munity and approval by the membership.

In a sense, the Regional Accrediting Commission helped to legiti-matize and rationalize changes in postsecondary education, per-forming a service for the academic community and society as awhole. A'

The intent is to maintain ,Atandards of quality while at the sanetime encouraging the flexibility which has been a major strength ofthe American system of postsecondary education. The Southern Association of Colleges and Schools is a nbnproflt corporation char-tered in Georgia, which conducts accrediting activities within a ge-ographical region that includes Alabama, Florida, Georgia, Ken-tucky, Louisiana, Mississippi, North Carolina, South Carolina, Ten-

f-\ nessee, Texas, and Virginia.Institutions of postsecondary education are accredited by the

Commission on Colleges, which accredits degree-granting, postsec-ondary institutions and by the Commission on Occupational Insti-tutions, which accredits nondegree-granting occupational educa-tional institutions. The number of member institutions accreditedby the Commission on Colleges, as I said, now stands at 723.

Of the 723 collegeS accredited by the Commission on Colleges, 435are public and 288 are private institutions. Including in our mem-bership are 77 historically black institutions. The total enrollmentof our member institutions is 2,514,854.

The validity and .equity of the accreditation process of the Com-mission depends in large part on that level of review which is car-ried out by the visiting evaluation committee. The philosophy ofthe Commission on Colleges has been to involve as many facultymembers and administrators from as many institutions as possiblein the evaluation process.

We have developed a list of approximately 4,700 evaluators whoare available for service on ow: committees. They currently repre-sent 688 institutions in our region. These peer volunteers are thereal strength of our regional accreditation.

We have been asked to provide our reaction to the findings con-tained in the Carnegie Foundation report on the governance ofhigher education. The major conclusion of the report is clear: Theacademic community must assume primary responsibility for itsown regulation if quality and independence are to be characteris-tics of our postsecondary institutions.

We agree that the academic community must be responsible forits own regulation and it is this aspect of the report that intimatelyinvolves our work in regional accreditation.

Certainly, the presidents of our member institutions would con-clude that there has been a diminution of institutional independ-ence as a result of the actions of State governments, the FederalGovernment, and the courts.

Tile Commission on Colleges has defended the autonomy ofmember institutions many times in the past, usually as a result of

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the actions of a Governor or a State legislator. These were charac-teristically dramatic instances. An action by the commission was.an important factor in resolving the diffictilties.

The challenge in our recent situation, however, is to.defend ourinstitutions against the accumulation of less dramatic intrusions.Those recommendations in the Carnegie report pertaining to therole of college governing boards, we support fully.

Goveihing boards have an important duty in protecting institu-tional autonomy. Our own standards of the Commission on Collegescall for the governing board to protect the college administrationfrom undue pressure from political or religious bodies.

The Carnegie report recommends that the preparation of an ap-proved list of regional associations be a function of the Council onPostsecondary Education, not the Federal Government. We concurand hope that much of the recognition of COPA could be utilizedby the Secretary of Education.

COPA is not without its imperfections; neither are its constituentmembers. It does, however, utilize a recognition process, the valid-ity of which includes the participation of not only those in accredit-ing, but by persons representing national postsecondary education-al organizations and the public.

The Carnegie report views regional accreditation as a criticallyimportant part of academic governance and recommends that offi-cials at all colleges should fully support the regional associations.We welcome and support this recommendation.

It implies, however, that regional accrediting associations cur-rently lack support from the academic community. We have notfound this to be the case. Administrators and faculty membersfrom our institutions value the process and consider serving on vis-iting committees and on the Commission on Colleges a significantmeans of professional development, as well as a responsibility.

During 1982, 130 committees, with a total of 880 evaluators, vis-ited candidate, member, or applying institutions. These evaluatorswere drawn from 378. institutions.

The Commission on Colleges is currently in the process of revis-ing all of its standards and procedures to give increased emphasisto institutional planning and the assessment of student outcome. Itbegan 2 years ago with a survey of over 2,600 individuals connectedwith higher education, and will culminate with a vote of the entiremembership in December of this year.

The Carnegie report states that regional accrediting associationsshould expand the scope of their authority and hold colleges ac-countable for good management, consumer protection, and affirma-tive action. We believe that we are it present holding colleges re=sponsible for good management, not only of human resources, butof physical and finandial resources as well.

Management, as it affects quality, is a primary concern in theevaluation process. We also believe that the most desirable consum-er protection we can provide is to help insure that students receivea quality education and that institutions accurately describe to stu-dents the nature of the college and what is to be expected of bothparties to the educational process.

116

It is not desirable, and probably would be impossible for regionalaccrediting associations to become involved in the intricacies of en-forcing the multitude of government regulations and gui(qelines.

There are few in postsecondary education who would desire tosee regional accrediting associations become a policing arm of gov-ernment.

4 The final recommendation on which we would like to comment isthe proposal that a court of last resort be organized by COPA tohear an appeal from an institution which believes that it has beenunfairly treated by a regional association. We believe this to be un-necessary because each regional commission has an adequate ap-peals procedure, a requirement for COPA recognition. COPA alsosolicits third -party testimony as part of the appeals process.

In conclusion, I would like to say that regional accreditation is ahighly coveted status for postsecondary institutions. Not only is itdesirable for reasons of prestige, because it is an important consid-eration when a student selects a college to attend, it facilitates thetransfer of credits and the admission of students to institutions ofhigher education levels, it gives guidance to employers who notonly hire graduates, but in many instances pay tuition for theiremployees. It is relied on by the Veterans' Administration and themilitary services in the funding of tuition. It is linked to institu-tional eligibility for Federal funding and it influences the fundingdecision of foundations.

It has been a pleasure to give you this testimony. I am alwaysenthusiastic when I have an opportunity to comment on regionalaccrediting and what it has, meant and continues to mean to post-secondary education.

[Prepared statement of Gordon $weet follows:]

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PREPARE :) STATEMENT OF' GORDON SWEET, EXECIFTIVE DIRECTOR. COMMISSION ONCOLLEGES OF THE SOUTHERN ASSEICIATIOIsI OF COLLEOES AN I1 SCHOOLS

I am Gordon Sweet, Executive Director of the Commission on Colleges of

the Southern Association of Colleges and Schools. The Commission on Colleges

accredits degree-granting postsecondary institutions in he South and I am

pleased to represent our 723.member colleges before Ibis Committee.

I have been asked to 'discuss the role and function of regional accreditation

and to comment on th' recent report of the Carnegie Foundation for the,

4Advancement of Teaching entitled "The Coqtrol of the Campus: A Report

on the Governance of Higher Education." 1 would like first10 offer some

general comments concerning regional accreditation,qhen describe how the

Commission on Colleges functions in the South,and.concludemith reactions

to the Carnegie, report.

To aid in understanding where we are-at present it is helpful to review

briefly the unique histpry of regional.accrediting. Regional accredi-

tation had its origins in the rapid societal changes. which took place

in the United States of the immediate Post-Civil War period. Higher

education was expanding: hundreds of new colleges were created. But

there was little uriformity or definition of a college in terms of admission

standards, curriculum, and length of study. The situation had become what

some educators termed chaotic. Business, industry, and tne professions

were unsure of the competence of the college graduates the, desired to

employ, and students who wanted to attend college had little guidance.

The formation of regional accrediting associations in the period

1885 to 1895 helper' to bring order to this situation. The four regional

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accreditirp associations founded during this period -- the Southern

Association of Colleges and Schools in,1895 -- and those founded later

were similar in nature. They wee and have remained voluntary,, private,

snd non-profit, and accredit institutions', not specific programs. The

strong feeling against governmental regulatory.action, egcially in regard

to education, made a voluntary accrediting organization the natural

vehicle to achieve a measure of uniformity and orde'r in postsecondary

education. The fact that they are organized regionally has enabled them

to escape the possible bias and provincialism of local or state organiza-

tions and, at the same time, to respond to regional trenus and needs.4 .

Cooperation and consultation among.the regional accrediting associations,

however, has existed from the early years both on an infwmal and a formal basis.

Regional accrediting associations have always been membership organi-

zations: Each accredited institution iS'a member and has the opportunity

to play a part in the development of standards and in the accreditng

process itself. By relying on volunteers from the postsecondary education

community in carrying out the work of accreditation, regional accrediting

associations can not only utilize those persons outstand.ng in the academic

community, but can -also operate with small staffs and thus avoid an

encumbering bureecracy.

Regional accrediting associations have assigned the task of accrediting

postsecondary institutions to commissions. The work of the regional

accrediting commissions on postsecondary education has traditionally focused

on two important objectives: the maintenance of minimum standards of quality

in postsecondary education and the stimulation of institutions to become

more effective thrnuqh self-study and examination. In discussing the maintenance

of minimum standards of quality it must be recognized that many of the

characteristics of a college which we take for granted today were shaped

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by the regional associations,along with such organizations as the Carnegie

Foundation for the Advancement of Teaching and the Association of American

Universities, as they worked to define those elements which should be

present for a college to be accredited as meeting minimum quality standards.

Among these elements, for example, is the standard four-year undergraduate

Curriculum.

Defining essential elements of a quality education has been a difficult

task through the years. It is, however, a crucial task and one that is

most effectively done by the academic community, with aperepriate consideration

for the needs of students, business, industry, and the professions. The

standards of all regional accrediting commissions have been revised many

times through the dears to respond to changing needS and practices in

postsecondary education.

For the regional accrediting commission on postsecondary education,

the work of developing standards and procedures for accreditation does not

proceed independent of society or the consumer of educational services.

Changes in the technology and methods in business and the professlons

create new demands and legitimate pressures for changes in the curricula

tv our institutions, or perhaps in the mode of delivery of educational

services. Curricula and methods of teaching appropriate twenty-five years

ago may not be adequate to meet the needs of today. These societal

.pressures are desirable: they prod our institutions to respond. Regional

accrediting commissions, relying on the academic community's perceptions

Of, and responses to these changes, make adjustments in standards and

procedures. But changes in the standards and procedures of the regional

accrediting commissions are not made capriciously. They are

accomplished only after intense study and discussion witnin the academiC

community and approval by the membership. The crucial cuncern in all

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revisions of standards has been to maintain quality in or colleges and

universities. This is done by incorporating in the standards current

commonly-accepted elements of good educational practice, and also by de-

signing the standards in such manner that they accomodate the future

in allowing for beneficial changes to take place. In a sense the

regional accrediting commissions help to legitimize and rationalize changes

in postsecondary education, performing a service for the academic community

and society as a whole. The intent is to maintain stanwrds of quality,

while at the same time encouraging the flexibility which has been a major

strength of the American system of postsecondary education.

I have mentioned legitimate pressures from society which result in

desirable change. There are also occasions when postsecondary institutions

have been subjected to outside interference in their internal affairs.

Regional accrediting commissions have served in the past to protect

institutions from political interference. Their ability to do this is

enhanced because of their nongovernmental nature and the fact that they

are regional in scope aid not subject to possible pressure from any one

state government.

The other major goal of regional accrediting commissions is to increase

the effectiveness of institutions through the self-study process. It is

not sufficient for an institution to be meeting the standards of the regional

accrediting commission. Periodically, institutions must conduct an inten-

sive institutional self-study, a study which analyses the strengths and

-*kweaknesses of the institution and produces recommendations for remedying

weaknesses and building on strengths. In essence a self-study becomes a

planning document for the institution and a tool for siqaificant institutional

improvement. The adequacy of the self-study is an important consideration

when an institution presents itself for reaffirmation of accreditation.

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The Southern Association of Colleges and Schools is a nonprofit

corporation chartered in Georgia which conducts accrediting activities within

a geographical region that includes Alabama, Florida, Georgia, Kentucky,

Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas,

and Virginia. Corporate powers are vested in a Board of Trustees whose members

include representatives from the various commissions of the Association,

and representatives from the public. The Southern Association of Colleges

and Schools accredits elementary and secondary schools through two commissions:

the Commission on Elementary Schools and the COmmission on Secondary Schools.

Institutions of postsecondary education are accredited by the Commission

on Colleges, which accredits degree-granting postsecondary institutions,

and by the Commission on Occupational Education Institutions which accredits

nondegree-granting occupational education institutions. The number of member

institutions accredited by the Commission on Colleges stands at 723, and

214 are accredited by the Commission on Occupational Education Institutions.

Of the 723 colleges accredited by the Commission on Colleges, 435 are public

and 288 are private institutions. The following is a breakdown by level:

320 institutions are accredited to offer the associate degree; 166 the

bachelor's degree; 126 the bachelor's and master's degrees; 92 the bachelori,

master-'s and doctor's degrees; and 19 offer graduate and professional

degrees only. Included in our membership are 77 historically BlaL., insti-

tutions. The total enrollment of our member institutions is 2,514,854.

Each member degree-granting institution is entitled to one vote in the

College Delegate Assembly of'-the Commission on Colleges. The College

Delegate Assembly is the body which approves all changes in the standards

for accreditation. The College Delegate Assembly elects the 66 members

of the Commission on Colleges, which oversees the work of accrediting,

according to the following formula:

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1. Two persons from each state and six persons at large, all connectedwith member institutions which offer bachelor's, master'sprofessional, or doctor's degrees.

2. Fifteen persons connected with member institutions which offerassociated degrees.

3. One person Connected with a member elementary or secondary school

'14from each state.

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4. Five persons from the region representing the lay public.

5. Seven persons elected at large from member institutions.

'Members of the Commission on Colleges are elected for terms of three

years. The formula for membership on the Commission on Colleges provides

for wide representation of: institutions by state, and at all degree levels;

by elementary and secondary school representatives; and by the lay public.

Provision for rotation ensures that a large number of educators become

intimately involved in the accreditation process.

Duties of the 66-member Commissiep on Colleges inclode: preparing the

standards for membership subject to approval by the College Delegate

Assembly, taking final action on the accreditation of collegiate institutions,

authorizing visits and investigations, and appointing special committees.

The Commission on Colleges acts on policy matters not related to changes in

the standards. An Executive Council of nine members is elected by the

Commission aneacts for the Commission when it is not in session.

Each of the members of the Commission on Colleges 1s a Volunteer and

is paid only expenses. Each serves on either the Standards and Report

Committee for institutions offering theassociate degree or the Standards

and Reports Committee for those offAing degrees above the associate.

Information and reports concerni)member and applying institutions

are submitted to these committees. For an institution which has no status

with the Commission on Colleges the following procedure$ apply in seeking

Candidate. for Accreditation status, the first'phase of the accreditation process.

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. 1. The chief executive officer of the institution interested inaccreditation writes the Executive Director of the Commissiondeclaring the institution's intent to be recognized as a Candidatefor Accreditation. The institution must provid: documentation ofcompliance with the Commission's Conditions of Eligibility.

2. An Application Form is then prepared by the institution. Thisreport describes institutional characteristics and resources. Ifthe report appears adequate a staff member will visit the institution.

3. A candidate committee may be authorized by the appropriate Committeeon Standards and Reports. The candidate committee visits theinstitution and reports to the Committee on Standards and Reportson the institution's potential for achieving accreditation within areasonable time. The Committee on Standards and Reports may recommendto the Executive Council that the institution be granted "Candidatefor Accreditation" status. If the Commission on Colleges approvesa favorable recommendation from the Executive Council the institutionis made a Candidate.

4. Candidates for Accreditation are required to file annual reportsand be visited by a staff member.

5. At two-year intervals a Commission committee visits the institutionto determine if Candidate status should be renewed.

After achieving candidate status the next step is for the institutionto apply for initial accreditation. The following procedures apply

1. Candidate institutions may apply for accreditation status afterono year. They are not allowed to remain in Candidate statusbeyond six years. If they are not granted an evaluation committeefor accreditation during this period, they are dropped from candidatestatus.

2. When an institution decides to seek accreditation status, itsupdated appli':ation form will be reviewed by the Committee on Standardsand Reports and an evaluation committee for initial accreditationmay be authorized.

3. The evaluation committee for initial accreditation visits theinstitution and submits its report to the Committee on Standards andReports. This Committee makes its recommendation on the grantingof accreditation to tie Executive Council which will refer itsrecommendation to the Commission on Colleges for final action.

An institution receiving initial accreditation must have its accreditation

status reaffirmed at the end of five years. This involves the following:

I. The institution is required to complete a comprehensive self-study.

2. An evaluation committee for reaffirmation of accreditation visitsthe institution at the completion of the self-study. Its report issubmitted to the Committee on Standards afid Reports which then makesa recommendation as to reaffirmation of ccredication to the

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Executive Council, which refers its recommendation to theCommission on Colleges for final action.

After this first five-year reaffirmation institutions are required to

repeat the reaffirmation process every ten years.

At every stage of this process institutions are advised by the staff

of the Commission on Colleges, and staff members accompany each evaluation

committee to aid in xhe coordination of the visit and to help ensure that

the the procedures of the Commission on Colleges are followed. Staff

members do not serve as eiraluators On each occasion when a committee

visits an institution, an exit conference is held with the chief executive

officer of the institution.. Institutions are invited le each instance to

respond in writing to reports of visiting committees, and the chief

executive officer is sometimes asked to appear before the appropriate

Committee on Standards and Reports.

There are other occasions when committees are sent to institutions.

This happens when, for example, a four-year institution requests that it

allowed to offer graduate work, or when it expands its off-campus programs.

Special evaluation committees may be authorized by one of the Committees

on Standards and Reports if significant problems develop in an institution

in relation to the standards of the Commission on Colleges. The costs of all

committee visits are borne by the institution which is being evaluated.

The two Committees on Standards and Reports, therefnre, have the important

task of reviewing all reports, and institutional responses to reports, of

visiting evaluation committees, whether part of the normal cycle of accreditation

and reaffirmation or resulting from special visits. ,Duties also involve

the requesting of, and review of, special follow-up reports by institutions,

and review of the fifth-year report required of each instiotion at the mid-

point of the reaffirmation cycle. Recommendations made by the Standards

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and Reports Committees may also include that of placing an institution on

probation because of non-compliance with the standards, or dropping it from

membership. Recommendations for negative actions are made to the Executive

Council, and its recommendation is sent to the CommisOlfor final action.

An institution may be placed on "notice" by the Committees on Standards

and Reports. This is a private status which is a warning that if deficiences

are not.remedied the institution may be placed on probation, a status which

'is published.

Institutions may appeal negative decisions by the Commission on Colleges.

An appeals committee of nine members with provision for rotation is elected

by the College Delegate Assembly from its membership. Nu person on this

appeals committee may be serving on the Commission on Colleges or its com-

mittees. The appeals committee has the power to affirm or reverse a negative.

action of the Commission, or to remand the case to the Commission for final

action.

Thevalidity and equity of.the review process at the levels of the Standards

and Reports Committees and th Commission depends in large part on that level

of review which is carried out by the visiting evaluitiOncommittees. These

committees of peer evaluators are drawn primarily from member institutions in

the South, but evaluators from outside the region are also used. The philos-

ophy of the Commission on Colleges has been to involve as many faculty mem-

bers and administrators from as many institutions as possible in the evaluation

process. We have developed a list of approximately 4,706 evaluators who are

available for sOti ice on committees. They currently represent 688 institu-

tions in our region. Computer access enables us to print out a card for each

of these 4,700 evaluators, with such pertinent information as academic and

administrative background, in addition to a record of eacn time the evaluator

has served and his rating by the chairman of the visiting committee and by

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the staff memberwho accoripanied the committee. Many of these evaluators

are trained in workshops conducted by the Commission. Experienced committee

members who have demonstrated skill and leadership ability are formally

trained as chairmen.

These peer volunteers are the real strength of regional accreditation.

They are paid a. small honorarium by the Commission on Colleges-450 for

members of a committee and $100 fcr the chairman--for what is normally a

three-day intensive working visit to a college campus. A few statistics

illustrate the scope of th'it volunteer effort. During 1982, 880 individuals

participated on visiting committees to applying and member institutions as

part of the peer review Process. These individuals were drawn from 378

institutions.

As par:t of the process of reaffirmation of eccreditation,institutions

produce an analytical self-study and are thin visited by a committee. The

committee is expected to evaluate the institution against the standards

of the Commission on Colleges and, in light of the institution's stated

educational mission, evaluate the adequacy of the self-study. They are

also asked to offer advice and suggestions helpful in the future development

of the institution. Committee members serve as both evaluators and consul-

tants. The recommendations of the visiting committees are considered

seriously by the Standards and Reports Committees. The staff of the Com-

mission on Colleges is very careful when putting together any visiting

committee. No evaluatnrs are drawn from the state in which the institution

to be visited it located. Visiting committee members have had no relation-

ship with the institution which might prejudice heir Judgment.

We are proud that the Commission on Colleges has been able to involve

so many educators at all levels of our accreditation rvcess. The flow of

educators from institution to institution is exciti not only because it

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\------13-grefTective method of self-regulation, but also because it results in

a cross-fertilization of ideas which in itself leads to institutional improve-

ment throughout the South.

We have been asked to provide our reaction to the findings contained

in the Carnegie Foundation report on the governance of higher education.

The major conclusion of the report is clear: the academic community must

assume primary responsibility for its own regulation if quality and indep-

endence are to be characteristics of our postsecondary institutions. The

report points out the detrimental effects of what it term an "ever-increasing

role of outside agencies in campus matters."

We agree tteat the academic community must be responsible for its own

regulation, and it is this aspect of the report that intimately involves our

work in regional accreditation. Certainly the presidents of our member

institutions would conclude that there has been a diminution of institu-

tional independence as a result of the actions of state government the

federal government, and the courts,. As the Carnegie Report rightly points

our, instances of interference have not been, for the most part, dramatic or

particularly odious, and have been accomplished with the best of motives.

But the cumulative impact of government intervention has been significant.

In 1976 the Commission on Colleges, because of a growing concern over

federal regulation, surveyed its membership to gather information detailing

the cost and problems involved with institutional comol4ance with federal

regulations and requirements. The report resulting from the survey concluded

that the quality of educational offerings to students was being affected

adversely by the necessity for federal compliince in a large number of

programs. Adding to the concern of our member institutions lately has been

the initiation in several southern states of accreditation and approval

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activities conducted by state agencies, resulting in duplication of effort

0

and a further burden being placed on the institutions.

The Commission on Colleges has defended the autoncmy of member insti-

tutions many times in the past; during the years when Governor HueyLong

directlyinjected himself into the affairs of Louisiana institutions, in

Kentucky and Georgia during the 1940's in similar situations; during the

early 1960's, the time of integration, when the Governor of Mississippi

took over as registrar of the University of Mississippi; and in 1963 when

the state of North Carolina prevented, those with certat political affilia-

tions from speaking,on,college campuses. These were dramatic instances, and

action by the Commission was an important factor in resolving the difficulties.

The challenge in our present situation, however, is to defend our institu-

tions against an accumulation of less dramatic intrusions. The burden of

this defense rests partly, and rightly so, on the shoulders of the thousands

of evaluators on our cemmittees whose responsibility is Insuring that our

institutions continue to operate without stultifying outside interference.

The Carnegie' report offers a number of recommendations in the chapter

entitled "A Governance Framework for Higher Education." Those recommoldttions

pertaining to the role of college governing boards we support fully. Govern-

ing boards have an important duty in protecting institutional autonomy.

Our own standards of the Commission on Colleges call for the governing

board to protect the college administration from undue pressure from poli-

tical or religious bodies. We would add eto these recommendations an encourage-

ment to governing boards to become more knowledgeable about the meaning and

processes of accreditation. This would help us considerably.

The recommendations in tai.: report directed to sta' governments are

useful. and. if adopted would help maintain theinstitutional autonomy we all

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desire. One recommendation calls for state coordinating agencies to work

closely with regional accrediting associations to evaluate theerformance

of each campus. We have tried to encourage this by notifying these .agencies

of accrediting visits and by allowing an institution to invite members of 4

the agency to be present during the visit to provide pseful information to

the committee.

The Carnegie Report recommends that the preparation' of an approved list

of regional associations be a function of the Council on Postsecondary

Accreditation, not the federal government. We concur, and would hope that

nuch of the recognition function of COPA could be utilized by the Secretary

of Education. From 1952 to 1968 the Office of Education, in publishing

its list of recognized accrediting agencies, relied on the decisions of

private accrediting agencies whose determinations were widely recognized in

the academic community as being sufficiently reliable for this purpose. It

was nGt until 1968 that the then Office of Education established a special

staff on accreditation and institutional eligibility, which began to0

-develop an extensive list of criteria accrediting agencies had to employoa

to be recognized. Phase criteria, unfortunately, have been expanded through

the years and we have often registered our objection.

COPA is not without its imperfections: neither are its constituent

members. It does, however, utilize a higqly developed recognition process,

the validity of which is enhanced by the participation of not only those

in accrediting, but by persons representing national postsecondary educe-4,)

tional organizations, and the public.

The Carnegie report views regional accrediation as a critically impor-

tant part of academic governance and recommends that officials at all col-

leges should fully support the regional associations. We welcome and support

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this recommendaticn. It implies, however, that regional accrediting associa-

tions currently lack support from the academic community. This implication is

-4 reinforced by statements in the report that "accreditation has increas-

ingly lost significance," that " accreditation review oftan is little

more than an empty ritual," and that "higher education.iaaders frequently

decline to participate in the process." We do not believe these state-

ments to be accurate. .AdAnistrators and faculty members from our insti-

tutions value the process and consider serving on visiting committees and

on the Commission on Colleges a significant means of professional develop-,

ment, as well as a responsibility. During 1982, 130 connittees, with a

total of 880 evaluators, visited candidate, member, or applying institutions.

These evaluators were drawn from 378 institutions. Included were evaluators

from:

University of AlabamaUniversity of FloridaFlorida State UniversityEmory UniversityUniversity of GeorgiaUniversity of KentuckyLouisiana State UniversityTulane Universit:,Davidson CollegeDuke UniversityUniversity of North Carolina at Chapel HillUniveHity of South CarolinaUniversity of .Tennessee at KnoxvilleVanderbilt UniversityBaylor UniversityUniversity of Texas at AustinCollege of William and MaryUniversity of Virginia

On the Commission on Colleges 60 institutions were represented, and 35

were repredented cn special committees.

The self-study process is also valued highly by member institutions.

A 1973 survey of chiuf executive officers of member institutions indicated

that, of those responding, 9ti.C. favored its continued use and an overwhelming

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majority believed it to be both useful and necessary. In a 1961 survey of

chief executive officers, of the approximately 95% who responded, 94% agreed

that'the self-study process was valuable ,and should be continued as a basis

of reaffirmation of accreditation. We have responded to requests from

university systems in three states tat we assist them in the development

of a system self - study, and that we evaluate the syitem and its self-study,

not for accreditation purposes, but for the benefit of the system. This

has also been the case in one large community college system.

The Carnegie Report also states that "among accreditOrs there is

no agreement about the meaning of a college education, the *neglect of under-

graduate education is especially disturbing." Everyone recognizes that

\there are disagreements as to the meaning of a college education and the

defin?tion of quality. These disagreements will continue. The standards

of the Commission on Colleges of the Southern Association of Colleges

represent an attempt to define the essential elements which the acadpmic

community believes must be present for a college to conauct a quality

educational program. Our standards, as is true with any standards, do not

please everyone, but they do define in many ways what a college education

should be, and they are certainly not neglectful of undergraduate education:

486 of our 723 institutions offer degrees only at the undergraduate level.

The eleven current standards of the Commission on Colleges speak to an

institution's purpose, organization and administration, educational program,

financial resources, faculty, library, student development services, physi-

cal resources, special activities, graduate programs. and research.

The Commission on Colleges is currently in the process of revising all

of its standards and procedures to give increased emphasis to the assess-

ment of student outcomes and institutional planning. This project began

with a survey in 1981 of over 2600 individuals, including chief executive

4

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officers of institutions, chief academic officers, visiting committee

members, officials of educational foundations; those in state and federal

agencies, and others with an interest in accreditation. The survey was conducted

to determine the effectiveness of the current accrediting process and ways

the process could be improved. Committees were appointed which involved

over 100 persons representing 75 member-institutions. These committees

gathered information, carefully reviewed the present standards and pro-

cedures, and drafted Proposed criteria for accreditation. The proposed

' criteria:were sent out for comment to selected individuals and reviewed by

the Commission on Colleges. The entire membership receiued for review

copies of the proposed criteria in December, 1932. In June, 1983 the

Executive Council of the Conmission willconsider input from the member-, ,

ship and make any needed revisions: The proposed, criteria for accredita-

tion will'be voted on by the entire membership at the annual meeting in

December, 1983. This revision process is an.arduous but necessary task. It

Is how the academic community goes about defining quality and establishing

procedures for evaluation.

The Carnegie Report leaves the impression that reyional accrediting

associations evaluate collegei, only on the basis of the objectives of the

college, without requiring them to meet standards of quality. For an

institution to be accredited by the Commission on Colleges it must be in

compliance with the standards. Educational programs offered should be in

accord with the stated mission and advertiiing of the institqtion. A college

of art, as well as a small liberal arts college, or a large complex state

university, is required to show that its curriculum and resources are appropriate

to its. mission, are sufficiently developed to satisfy the standards, and are

in congruence with what is currently-accepted good practice according to the

academic coffnunity.

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The Carnegie Report states that regional accrediting associations

should expand the scope of their authority and hold colleges accountable

for good management, consumer protection, and affirmative action. We

believe that we are currently holding colleges responsible for good man-

agement, not only of human resources, but physical and financial resources

as well. Management, as it effects quality, is a primary concern in the

evaluation process. We also believe that the most desirable consumer pro-

tection we can provide is to help ensure that students receive a quality

education and that institutions accurately describe to students the nature

of the college and wh..% is to be expected of both parties to the educational

process. It is not desirable, and probably would be impossible, for

regional accrediting associations to become involved in the intricacies of

enforcing the multitude of government regulations and guidelines. The

complexities and difficulties faced in enforcing affirmative action in

postsecondary education are also apparent. Enforcement of government

regulations and affirmative action should be the purview of government, or

if necessary, the courts. There are very few in postsecondary education

who would desire to see regional accrediting associations become a policing

arm of government.

A further recommendation of the report is that information about the

accreditation of colleges should be more accessible to the public. At

Present our Commission on Colleges publishes the fact that an institution

has been placed on probation or dropped from membership, and cites the

standards with which the institution has failed to comply. We agree that

more information should be provided. The regional commissions have agreed

on this point and are working to accomplish it without violating confidential

information.

A final rocummandetion on which we would like to comment is the proposal

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that a court of last resort be organized by COPA to hear an appeal from

an institution which believes it has been unfairly treaisd by a regional

amciatiun. We believe this to unnecessary because ea:h regional commission

has an adequate appeals procedure, a requirement for COPA recognition.

COPA also solicits third-party testimony as part of the recognition process.

In conclusion I would like to say that regional accreditation is a

highly coveted status for postsecondary institutions. Not only is it

desirable for reasons of prestige, but because: it is an important con-

sideration when a student selects a college to attend; it facilitates the

transfer of credits and the admission of students to institutions at

higher degree levels; it gives egidance to employers, who not only hire

graduates, but in many instances pay the tuition of their employlps; it is

relied on by the Veterans Administration and the military services in their

funding of tuition; it is linked to institutional eligibility for federal

funding; and it influences the funding decisions of founJations.

It has been a pleasure to testify before you today. I am always

enthusiastic when I nave an opportunity to comment on regional accrediting

and what it has meant and continues to mean to postsecondary education.

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Mr. HARRISON. Thank you very much, Dr. Sweet. I think our tra-dition here is to go through the panel and then come back. Perhapswe will have some questions at a later time.

Dr. Manning.

STATEMENT OF THURSTON E. MANNING, DIRECTOR,COMMISSION ON INSTITUTIONS OF HIGHER EDUCATION

Mr. MANNING. Mr. Chairman, members of the subcommittee, Iam Thurston E. Manning, the director of the Commission on Insti-tutions of Higher Education of the North Central Association ofColleges and Schools. That is quite a mouthful and I do not blamethe staff for leaving all of it off the agenda.

North Central Association, like the Southern Association, is oneof the six regional voluntary accrediting associations in the UnitedStates. Our geographic territory in North Central is 19 States inthe central part of our country, running from West Virginia on theeast to Arizona on the west, the Canadian border to the north,through Oklahoma and Arkansas on the south, the Midwest andthe associated parts of the United States.

In that region, the North Central Association accredits some5,000 elementary, junior, middle, and secondary kchools through itscommissions on schools, and some 915 colleges and universitiesthrough the Commission on Institutions of Higher Education. Wealso have 46 institutions, postsecondary institutions, that are incandidacy at this point.

As the chairman requested, I have divided my testimony intothree parts, first, describing North Central's criteria and proce-dures; second, the meaning of accreditation and what loss of ac-creditation might entail to an institution; and third, some comements on the Carnegie Foundation report.

I have, of course, prepared a written statement which you havefor the record and all I will try to do here is summarize somepoints about that statement.

Mr. HARRISON. Without objection, your written statement will beincorporated into the record.

Mr. MANNING. North Central Association first began accreditingcolleges and universities in 1913, 70 years next month to be moreexact about it. Obviously, things have changed in 70 years. Theprocedures and criteria that are used in 1983 are quite differentfrom those that were used in 1913.

However, for about 50 years, North Central, like the other re-gional accrediting organizations, has based its accreditation on afundamental principle that an institution should be judged in thelight of its own appropriate and stated purposes. The basic reasonfor this principle is that it allows for diversity in higher educationin the United States and the adoption of it really rests on the beliefthat only by providing a diversity of postsecondary institutions canthe diversity that is necessary and characteristic of American soci-ety be maintained.

We cannot serve society well by forcing all colleges and universi-ties into the same mold, regardless of how well-conceived that moldmay be. Sometimes that basic principle is misunderstood and dis-

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torted. I think this appears at one point in the Carnegie Founda-tion report.

It is assumed that if you want to judge an institution on thebasis of its own stated purposes, that anything goes. One couldhave a school for thieves, for example, which would meet its ownstated purposes and therefore be accreditable. Of course, that is nottrue.

We emphasize the basic principle so much that we may overlookemphasizing that we do far more than simply judge on the basis ofstated purposes. For one thing, we judge the purposes. Are they ap-propriate to a postsecondary educational institution? That is one ofthe basic criteria utilized by North Central and the other regionals,the question of appropriateness of the criteria.

Second, there are explicit general institutional requirements, aswe call them in North Central, which specify elements of organiza-tion, management, basic principles that experience has shown arenecessary for any successful postsecondary institution or one thatfalls within our scope of activity.

For example, we require a regular external audit of financial'statements. We require the fair and accurate disclosure of informa-tion for students and the public. We require the presence of publicrepresentation on the governing board of the institution.

All of those matters are explicit requirements which clearly gobeyond merely judging an institution in the light of its own activi-tic.a.

Ow procedures are very similar to those utilized by the SouthernAssociation, the other regional associations which Dr. Sweet hasdescribed. Reliance on self-study by the institution, a visiting team,drawn from persons from other accredited institutions, a reviewprocess, final decision by an executive board, and then an appealprocess outside of the commission established through the board ofdirectors of the association.

Accreditation, of course, is a public stamp of approval. It indi-cates that the institution has been examined by a qualified, inde-pendent group of peers and found to be meeting appropriate pur-poses in a satisfactory manner. It provides assurance to thosewithin the institution that their work is regarded as desirable andsatisfactory and assurance to those outside the institution that theinstitution performs useful activity for the benefit of society.

Public approval has been accepted as a basis for action by manygrooPs and consequently loss of accreditation can have serious con-sequences because it is loss of this basic indicator of quality. As Mr.Sweet has indicated, an accredited institution can recruit studentsmore easily because the students can have confidence that the in-stitution has been examined and found to be of a reasonable qual-ity.

Students can also expect from an accredited institution a betterchance that their credits will transfer or that they will be acceptedinto another institution for an advanced degree. Accreditation isoften used by private industry as a basis for reimbursement for tu-ition by States for State financial aid or grants to institutions, and,of course, as a basic threshold eligibility requirement for Federalprograms, both institutional grants and grants for student finan-cial aid.

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Consequently, loss of this basic indicator of public quality has aneffect. All of these things tend to fall if that indicator is lost. Theindication of accreditation, then, as a public indicator is what itmeans and loss of that indication has serious consequences.

Let me turn now to the Carnegie Foundation report and not tryto deal with all of the recommendations, but just with a few thatpertain to accreditation. In.gener.al,j thinjc,the..report is a valuabledocument. Its principal thrust, as I read it, is to describe the wayin which a growing body of State and Federal regulations and stat-utes now so restrict colleges and universities that they have lostmuch of their ability to change and respond to new needs of soci-ety.

The report recommends addressing this problem by returning toa greater reliance on self-regulation by institutions acting forthemselves and through voluntary associations, such as the accred-iting bodies. I agree with this general conclusion and with this rec-ommendation, but I do not underestimate the problem of disentan-gling all the many threads of statutes and regulations that havenow formed these heavy ropes that bind colleges and universities.That is another question.

I think the report in many cases understates the current activityand the strength of the accrediting associations. For example, ofthe 650 persons who form the pool from which we draw our visitingteams, our review committees, our executive board, I counted overthe last weekend some 200 persons who are chief executive officersof their institutions, another 200 who are the principal academicofficers, vice presidents, and deans, out of that group.

Of the 12 persons on our executive board who are drawn frompostsecondary institutions, 7 or them are presidents, and the boardis chaired by the president of the University of Nebraska. So Ithink the statement in the report that leaders of higher educationdo not participate in accreditation, in fact, is not the case and isnot supported by reasonable data.

Similarly, I think that the report understates the activity of ac-creditation or overstates its position, however you want to put it,when it says that we do not pay attention to such things as affirm-ative action, provision of fair and accurate information and mat-ters of that sort.

The accrediting agencies are not enforcing agencies for Federalor State statutes and regulations. We do, in fact, pay attention tothese matters and we have policy statements that deal with thesematters explicitly. I have already mentioned that we have somespecific requirements pertaining to these.

An examination of our team reports shows that the teams takethese things seriously and do draw them to the attention of the in-stitutions. The "Federal connection," as the Carnegie report callsit, between accreditation and eligibility has been from time to timea controversial issue.

I agree with the report's recommendation that continued reli-ance on accreditation as a threshold criterion for eligiblity is desir-able. It was put in place in the 1950's as a result of the abuses thatarose during the administration of the GI bill of World War II. Thefact that these abuses have not been repeated, except in isolatedinstances, is an indication, with 30 years of experience, that this

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was a wise piece of Federal legislation and one that should be con-tinued.

As part of this reliance, the Secretary of Education maintains alist of accrediting bodies, as you know. The report suggests that theSecretary should use instead the list of accrediting bodies recog-nized by the Council on Postsecondary Accreditation. I do not fully

-------agree with this recommendation:While accrediting bodies would welcome the disappearance of the

present duplication of two recognition processes, we come to theSecretary and we also go to COPA, though we go to COPA volun-tarily, come to the Secretary voluntarily, too, I suppose, there aregood reasons for both. I think the Federal Government, as Dr.Ambach indicated, must assure itself about the accreditation thatit uses. It can do this either by examining the accrediting bodiesdirectly, which is what it does now, or it can take COPA's word for'it, provided it supervises the regulatory process of COPA.

Now this latter alternative, I think, opens up all kinds of newproblems and I think solving those problems would not be worththe price that one would pay to work through all the details.

The present spirit of cooperation between the Council and thestaff of the department that deal with this problem, let me put itthis way, however, opens up a new possibility, namely the use of asingle submission to both groups. Each group, the Secretary on theone hand, COPA on the other hand, could make its separate deci-sion, but the accrediting bodies would be.spared the difficulty andthe task of putting together two separate but somewhat duplicativesubmissions.

No new legislation would be necessary for this. All that is reallyneeded is a spirit of cooperation between the two organizations inestablishing a common set of requirements against which to meas-ure tfie_.accrediting bodies.

Mr. Chairman, let me thank you and the subcommittee for theopportunity to testify. I think the time is right for a reconsider-ation of the many regulations that currently restrain institutionalgovernance. The Carnegie report points to many of these.

In the interest of the subcommittee in addressing the matters, itis heartening and encouraging to all of us.

[Prepared statement of Thurston Manning follows:]

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PREPARED STATEMENT OF' THURSTON E. MANNING, DIRECTOR, COMMISSION ON INSTI-TUTIONS (0.' HIGHER EDUCATION, NORTH CENTRAL ASSOCIATION OF COLLEGES ANI)

'SCHOOLS, CHICAGO, 11.1..

Mr. Chairman, Honorable members of the SUbcommittee on Postsecondary Education:

I am Thurston E. Manning, Director of the Commission on Institutions of Higher Education

of the North Central Association of Colleges and Schools. 1 thank you for the opportunity

to appear before the Subcommittee on behalf of the Association and the Commission. The

North Central Association accredits elementary, junior/middle, and secondary schools

through its Commission on Schools, and postsecondary institutions through its CoMmission

on Institutions of Higher Education. The geographical territory of the Association is the

nineteen states of Arizona, Arkansas, Colorado, 111;nois, Indiana, Iowa, Kansas, Michigan,

Minnesota, Missouri, Nebraska, Nivo Mexico, North Dakota, Ohio, Oklahoma, South

Dakota, West Virginia, Wiscons::1 and Wyoming; this area is the center of our country, from

West Virginia on the East through Arizona on the West, and from the Canadian border on

the North through Oklahoma and Arkansas on the South. North Central accredits in this

region some 915 colleges and universities, with an additional 46 institutions affiliated as

candidates.

In response to the request of the Chairman, this testimony is divided into three sections;

the first dealing with the criteria and procedures used by North Central 1.2 accredit a

postsecondary institution; the second with the questions what accreditation means to an

institution and what withdrawal of accreditation could lead to; the third with my

reactions to the findings and recommendations contained in the Carnegie Foundation

report, The Control of the Campus.

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Testimony of T. E. Manning for Subcommittee on Postsecondary Education - Page 2

1. Criteria and Procedures Used to Acfcredit a Postsecondary Institution.

The first list of colleges and universities accredited by the North Central Association was

published in 1913. The criteria used some seventy years ago strongly affected the

development of higher education, and over the years the criteria were changed and

adapted to the changes that had occurred. As a result of an extended study conducted by

the Association in the early thirties the Association adopted as a fundamental principle

that an institution should be judged in the light of its own stated purposes. This principle

still underlies the accreditation of postsecondary institutions, not.only by North Central

but alter; all other postsecondary institutional accrediting bodies. It is an expression of

the generally accepted view that the diversity of American society is served best by a

diversity of educational institutions. This diversity cannot exist if all institutions are

forced into the same mold by any sinZ set of external standards, however well

intentioned such standards might be. There is a substantial store of experience and data

supporting this point of view.

But the principle of judging an institution in the light of its own purposes does not mean

that "anything goes:" that an institution is accreditable if its meets its purposes, whatever

those purposes may be. An essential part of the accreditation judgment -- sometimes notNIIIIIDEM.....M.M1m.111101=11

sufficiently emphasized is a judgment of the institutional purposes themselves: are they

appropriate to a postsecondary educational institution. A further essential of the

accreditation judgment is whether the institution meets certain minimum requirements of

organization and of good practices in its operations -- requirements that experience has

shown are appropriate to all institutions that provide satisfactory postsecondary education.

The Commission most recently reviewed and revised its criteria in 1930. The criteria

currently consist of two sections: a set of General institutional Requirements, which both

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accredited and candidate institutions must meet, and a set of Evaluative Criteria, which

differ for accredited and candidate institutions. The General Institutional Requirements

specify the minimum requirements of organization and good practice; the Evaluative

Criteria provide the basis for judging the institution against its stated and appropriate

purposes.

The thirteen General Institutional Requirements are:

Requirements of institutional program:

The Institution

1. Has formally adopted a statement of mission appropriate to a postsecondary

educational institution;

2. Offers one or more programs (or curricula) consistent with that mission, including

general education at the postsecondary level as an essential element of, or a

prerequisite to, the principal program(s);

3. Has adopted a statement specifying the potential students it wishes to serve, and

admits students to its programs under admissions policies compatible with this

statement and appropriate to the programs;

4. Enrolls students in at least one postsecondary educational program normally requiring

at least one academic year for equivalent) for completion, and has students actively

pursuing such an educational program at the time of the Commission's evaluation;

5. Awards to each person successfully completing an educatibnal program a certificate,

diploma or degree appropriately describing the demonstrated attainments of the

graduate.

.

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Beguirements of organization:,

The institution

17.#1.r"7111..rtiPitIlt.

6. Has a charter and/or other formal authority from an appropriate governmental

agency authorizing it to award any certificate, diploma or degree It awards;

7. Has all necessary operating authorities in each jurisdiCtion in which it operates;

8. Has formally designated a chief executive officer, or has formally organized and

staffed a chief executive office;

9. Has a governing board that includes representation reflecting the public interest.

Beguirements of operation and public disclosure:

The institution

10. Documents a funding base, financial resources, and plans for financial development

adequate to carry out its stated purposes;

11. Has its financial records externally audited on a regular schedule, and makes

available to the public on request the most recent report of the external auditor (or a

fair summary thereof), including the auditor's opinion;

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12. Makes freely available to all Interested persons (and especially its present and

prospective students) accurate, fair, and substantially complete descriptions of its

programs, activities and proceduris;

13. Will have completed at least one complete cycle of Its priincipal programs before the

Commission's evaluation for accredited status.

The Evaluative Criteria for Accreditation are

1. The institution has clear and publicly stated purposes, consistent with its mission and

appropriate to a postsecondary educational institution;

2. The institution has effectively organized adequate human, financial and physical

resources into educational and other programs to accomplish its purposes;

3. The institution is accomplishing its purposes;

4. The institution can continue to accomplish its purposes.

The four Evaluative Criteria for Candidacy for Accreditation are:

I. Tnt. Institution has clear and publicly stated purposes, consistent with Its mission and

appropriate to a postsecondary educational institution;

2. The institution has effectively organized adequate human, financial and physical

resources into educational and other programs to accomplish its purposes;

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3. The institution Is following realistic plans to acquire and organize any additional

resources needed to accomplish its stated purposes;

4. The institution has the potential to achieve accreditation within the candidacy period.

It will be observed that the Evaluative Criteria for Candidacy are closely related to those

for accreditation, but are appropriate for an institution not yet fully enough developed or

experienced to achieve accreditation.

The criteria are applied to an institution through a process that Involves several steps:

1. The institution subjects itself to its own self-evaluation, seeking to gather

information bearing on the criteria, and to make changes and improvements in its

activities as it evaluates itself against the criteria. The institution documents this

study in an extended document which serves as a basis for the following steps.

2. The Commission appoints a visiting team ,composed of persons from accredited

institutions. This team visits the institution, ,:onducting interviews and examining

written records to supplement the information contained in the institution's

self-study doci,:nent. The visiting team prepares a written report on Its findings anda

prepares a recommendation for the Commission's action. The visiting team also

provides counsel to 'the institution. The institution is invited to respond to the team's

findings and recommendation. ,..

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3. The institution's self-study document, the team report and the institution's response

are reviewed through the Commission's review process, using other persons from

...accreated. _institutions, ..The..seview, process... may .. result in additional

recommendations for consideration in the Commission's action/he institution is

Invited to respond to any additional recommendations

4. The Executive Board of the Commission, comprising twelve persons elected from

accredited institutions and two public members, considers the full set of written

materials and recommendations and adopts a final accreditation action in .the name

of the Commission:

3. The institution may appeal from the Commission action to a separate appeal body

established outside the Commission by the Association Board of Directors. U an

appeal is denied the Commission action stands; if the appeal is sustained the case is

returned to the Commission for correction of the errors found and reconsideration of

the action.

Through this rather elaborate process the Commission provides for the exercise of

professional judgment on the question of whether an institution meets the criteria. The

institution is provided ample opportunity to present its case, and the Commission provides

for consideration by several different groups of persons drawn from accredited

institutions, thus helping to insure that the final action represents the general opinion of

qualified persons, and is not unduly influenced by the views of individuals or of particular

groups. The process is one of peer review: persons from accredited institutions judging

another institution. There is substantial evidence that these criteria and the process of

applying them meet with the general approval of the higher education community.

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2. Millet Accreditation Means to an Institution

and What Withdrawal of Accreditation Could Lead to.

The accreditation of an institution is a public stamp of approval indicating that the

institution has been examined by a qualified, independent group of peers and found to be

meeting its appropriate purposes in a satisfactory manner. Like any meaningful

expression of approval accreditation is valued by an institution. It provides assurance to

those within the institution that their work is regarded as desirable and satisfactory. It

provides assurance-to those outside the institution that the institution performs useful

activity for society.I

This public approval has been accepted as a basis for action by many groups. Students use

accreditation as an indicator that an institution offers a satisfactory level of educational

activities. Those who provide financial support to students -- parents, employers, states

and the federal government use accreditation as an indicator that the education offered

an accredited institution is of satisfactory quality and therefore a good investment.

Other institutions are far more likely to accept for transfer or admission to higher

degrees credits earned at an accredited institution. In short, accreditation serves as a

basic indicator of quality within an Institution and is used by those concerned with

Institutional quality.p

Loss of accreditation will have significant effects on an institution because it is the loss

of this basic indicator of quality. The institution will have difficulty, ,recrulting students,

who will no longer have the assurance of aproRram of acceptable quality. Parents will be

less willing to provide financial support for students to attend an unaccredited

institution. Many employers. provide tuition reimbursement and other forms of financial

assistance to employees attending only accredited institutions. Many states

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11.1,

provide financial assistance to students only at accredited institutions. Most programs of

federal financial assistance (both sudent aid and institutional grants) are restricted

generally to accredited institutions (although the federal government has provided certain

alternatives to accreditation). In shoesrt, lass of accreditation leads to a diminished public

credibility for an institution, and diminished credibility has Important consequences.

It must be kept in mind that accreditation is a pass-fail judgment: an accredited

institution Is certified merely as being of at least acceptable quality. As is true for all

such pass-fail judgments, most of those that pass of are substantially higher quality than

is required for mere passing. For these institutions the process of accreditation has

assumed a greater importance than the certification of accreditation. Through the

process an ins :tntion is stimulated to thorough and extensive self-evaluation and provided

with external counsel from qualified persons from other accredited institutions. This

process demonstrably encourages desirable changes and improvements in an institution,

however high its quality may be. Thus, even for institutions that are clearly accreditable,

the process of accreditation is a desirable one. It is for this reason that accreditation is

regarded by institutions as a useful activity, and accreditation is supported by virtually all

postsecondary institutions.

3. Comments on the Carnegie Report

The Control of the Campus, subtitled "A Carnegie Foundation Essay," was published by

the Carnegie Foundation for the Advancement of Teaching in late 1982. It is a valuable

study, providing in its first part a useful historical summary of the development of the

present conditions of institutional integrity and public accountability, and in its later

sections numerous recommendations for modifications in present conditions.

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The historical summary shows clearly how present constraints on institutions of higher

education have grown bit by bit over many years. Taken one by one, the constraints

imposed by the states and the federal government through statutes azd regulations appear

reasonable. But, as the Carnegie Report makes clear, the present situation is one in

which colleges and universities find theinselves so restricted by the demands of multiple

statutes and regulations that they have lost much of their ability to change and respond to

new needs of society. Each individual requirement is a slender thread, reasonable in

Itself. But taken together these threads have formed heavy ropes constraining reasonable

and necessary freedom. The report properly call for reasonable relief from these

constraints so that institutions can serve society appropriately. A principal means of

relief described in the Report is a return to greater self-regulation by institutions acting

by themselves and through voluntary associations, such as the accrediting bodies. I agree

with this general conclusion and recommendation.

Each of the many recommendations in the Report deserves attention. For reasons of time

I can mention only some of those directed specifically at accreditation.

Certainly no objection can be raised to the general thrust of these recommendations. But

I think that the Report does not correctly describe the present circumstances in its

discussion on pages 76-78. Our experience in North Central does not support the Report's

comment that 'higher education leaders frequently decline to participate!' in the

accreditation process. Our roster of some 650 persons who serve on our visiting teams, in

our,review processes, and on our Executive Board includes over 190 college and university

presidents, and another almost 200 chief academic officers -- deans and vice presidents.

Our Executive Board is currently chaired by the President of the University of Nebraska,

and counts seven presidents among its twelve institutional members. All these persons

devote each year many days of hard work to accreditation.

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As I have discussed earlier, and contrary to the statement of the Report (page 77)

accreditation does more than "measure a college against its own objectives."

While accrediting, bodies are not enforcement agencies for federal or state requirements

for manager.,nt, affirmative action and consumer protection, we do pay attention to

these matters, contrary to the implication of tile Report (page 77). Our General

Institutional Requirements speak explicitly to the presence of public representation on

governing boards and to the public disclosure of financial and other information of

importance to educational consumers, among other things. North Central has a general

policy as follows:

"The Commission expects an affiliated institution to evaluate its policies and

practices relating to such things as protection and nondiscrimination, monitoring of

student financial aid, mediation of internal strife and institutional sponsorship of

nonacadeinic activities. Therefore, a visiting team may include assessment of such

practices and policies in its evaluation of an institution, and may comment on such

matters in its written report."

Examination of our team reports shows that our evaluators takes such matters seriously

sometimes to the discomfort of an institution being evaluated.

Of course no accrediting body is perfect. Accreditation and institutional evaluation are

difficult and demanding tasks, and like other human enterprises we fall short of our

ideals. The comments in the Report are valuable in providing an additional spur to our

improvement, as well as a support for the goals we have set.

22-141 0-84--10153

150

I fully agree with the Report's recommendation (page 77) that "information about the

accreditation of colleges shOuld be more accessible to the public." The balance between

confidentiality, needed for full access to information, and public disclosure, needed for

continued credibility and usefulness of accreditation, has been struck too far toward

confidentiality, in my view. These are issues under active consideration. The Council on

Postsecondary Accreditation has a special committee studying the matt:er of public

disclosure, and we trust that it will produce recommendations that can be embraced by all

accrediting bodies. Within North Central we have examined the kinds of information that

should properly be public, and will be considering a new policy statement in April.

The "federal connection" between accreditation and eligibility for federal funding has

been the subject of much discussion and rsome_sa.a.oLeuagree with the position of

the Carnegie report (page 82) that we should maintain the reliance of the federal

government "on the academy itself -- through voluntary accreditation -- to determine

which colleges are eligible to get federal support." The experience of abuses arising from

the G.I. Bill of World War II which gave rise to this, reliance -- shows that a test of basic

institutional quality is necessary. Certainly there are problems in the present

arrangements, but, as the Carnegie Report notes (page -82), "This procedure is not perfect

but it is better than having the Department of Education evaluating colleges. . ." The

explicit recommendation (page 83), "In determining the eligibility of colleges to

participate in federal programs, the Secretary of Education should use- regional

accreditation as the basis for approval," needs to be widened to Include the institutional

accreditating bodies other than the regionals that now appear on the Secretary's list, since

these bodies provide accreditation to many worthy institutions lying outside the scope of

the regionals.

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An essential part of this process is.the listing of accrediting bodies whose accreditation Is

accepted for purposes of federal eligibility. The Report recommends (page 83), "The

preparation of an approved list of regional associations should be a function of the Council

of Postsecondary Accreditation, not the federal government." I do not fully agree with

this recommendation. Certainly it would be helpful if the present duplication existing in

the independent recognition processes of the Department of Education and of the Council

could be eliminated. But it seems to me that the federal government must assure itself

about the accreditation which it uses for decisions about financial aid. This cannot be

done unless federal officers either examine the accrediting bodies directly (as is now

done), or else supervise the recognition process of the Council. I think this latter

alternative presents new problems, and dealing with them will cost more than the value of

the advantage gained. The present spirit of cooperation between the Council and the

Eligibility and Agency Evaluation Staff of the Department opens a more attractive

opportunity: the use of the same submission by the accrediting bodies to the Council and

the Department, allowing each to make its separate decision, but eliminating the

duplication of submissions now required of the accrediting bodies. This procedure would

require not new legislation, but simply cooperation between the Council and the

Department in settling on a common list of requirements against which to measure the

accrediting bodies.

Let me again express my thanks to the Subcommittee for the opportunity to testify. The

time is ripe for a reconsideration of the many regulations that currently constrain

' institutional governance. The Carnegie Report points to many places at which

improvement can be made. The interest of the Subcommittee in addressing these matters

is heartening to all in higher education.

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Mr. SIMON. Thank you, Dr. Manning. My apologies to the firsttwo witnesses for my absence.

Dr. Phillips.

STATEMENT OF JAMES M. PHILLIPS, EXECUTIVE DIRECTOR, AC.CREDITING COMMISSION, ASSOCIATION OF INDEPENDENTCOLLEGES AND SCHOOLS, ACCOMPANIED BY ROBERT KLINE,CHAIRMAN; AND WILLIAM C. CLOHAN, JR., GENERAL COUNSELMr. PHILLIPS. Thank you, Mr. Chairman, members of the com-

mittee. I am James Phillips, executive director of the AccreditingCommission for the Association of Independent Colleges andSchools. As indicated earlier, I am accompanied today by Dr.Robert Kline from South Carolina, who is chairman of the Accred-iting Commission and Mr. William Clohan, who is our general legalcounsel and former Under Secretary of Education.

1 would like to give just a brief historical overview as Dr. Klinecan talk to you about the procedures and then comment briefly onthe Carnegie recommendations. Also, if I may, I will clarify acouple of statements that got into the testimony here on Tuesdaythat we feel were either misunderstood or inaccurate.

We do consider the schools that we represent to be a significantsector of the postsecondary education community of this country.The recent Carnegie study failed to recognize or dwell at anylength at all on our sector of postsecondary education. It lumped usfor listing purposes between two very specialized programmaticagencies. We have mixed feelings about that. We do not mind beingignored for the right reasons. We are concerned that perhaps theoccupation sector of postsecondary education in this country is con-tinuing to be ignored by the so-called traditional sector of highereducation.

I would like to address that just very briefly by saying that thereport mentions 3,100 accredited institutions, and I think it justrefers to them as institutions, not colleges and universities. I callthe attention of this committee to the fact that there are twice thatmany accredited occupational institutions in the country.

That is the sector, by and large, with which our association deals.Ninety percent of our accredited institutions are taxpaying busi-ness corporations. We have been listed by the Department of Edu-cation as a recognized accrediting body since 1956. Today we have571 schools and colleges and another 174 branch campuses thathave been thoroughly evaluated and accredited by our organiza-tion. All of these are private institutions.

They" range in types from specialized business programs of lessthan 1 year in length all the way to institutions offering graduateeducation. We estimate that there are 400,000 students today en-rolled in our sector of institutions. Nearly all of the graduatesavailable for employment ' finishing their training at our institu-tions do, in fact, become employed in occupations, professions, andservices, including self-employment, for which they have beentrained.

I will ask Dr. Kline to discuss just briefly with you the processthat we utilize which almost is similar to those already describedby the regional accrediting representatives.

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Mr. KLINE. Thank you, my name is Dr. Kline. and I am chairmanof the AICS Accrediting Commission and a professor of business ad-ministration at Winthrop College.

I am going to talk about three things: the accrediting process, alittle bit about the educational community's involvement in thatprocess, and also briefly about denials, withdrawals, and litigation.

The AICS Accrediting Commission is broadly representative ofeach of the types of institutions that we accredit. The accreditingcommission also includes three external members who are not fromaccrediting institutions, and usually from collegiate schools of busi-ness. I happen to be one of those members who is from a nonaccre-dited school.

In addition, there are public members who are appointed, and wehave another one to be appointed this year. In addition to this,there is an outside advisory committee to the commission consist-ing of traditional and vocational educators, representatives of thegeneral public, and representatives of students.

The policies and procedures in criteria over which our institu-tions are evaluated are more similar than dissimilar to those em-ployed by regional accreditation. We encourage institutions to con-tinue self-monitoring and improvements of the accrediting processin areas such as student relatips, academic programs, facultyqualifications, inservice training,s administrative capabilities, andsupervision of student financial aid programs.

We believe that it is important for members of this committee, aswell as all Members of Congress, to understand and, hopefully,accept the fact that accrediting bodies simply cannot monitor aninstitution's day-te-day compliance with the myriad of Federal reg-ulations associated with the administration of Federal financialaid.

Accreditation is, and sheuld continue to be, relied on as a thresh-old requirement for student aid participation. There .always is as-sessment by department beyond accreditation before eligibility isestablished.

We use a variety of outside people to be involved in the accredit-ing process, representatives of all groups. We have a waiting list ofindividuals throughout the country, both from AICS-accredited in-stitutions, and from outside institutions that work on the accredit-ing teams and visit the institutions.

There is a frequent criticism in that nearly all institutions areaccredited, and very few ever lose accreditation, therefore the proc-ess is meaningless. This is simply not ,true. AICS has refused to ac-credit many institutions because they fail to meet the criteria. Wealso routinely withdraw accreditation from institutions that nolonger meet these guidelines and each and every withdrawal ispublished.

I will turn it back to Jim.Mr. PHILLIPS. Briefly, on the Carnegie report and some of its rec-

ommendations, we, too, as do my colleagues, support some of thesuggestions and recommendations for change and/or improvementin that report.

Most of the criticisms of accreditation in that report are reallynot new. Historically, we have heard them going back for yearsand years. Historically, and traditionally also, during economic

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hard times, accreditation gets criticized along with other education-al processes more than at other times. You can trace the history ofthis in the 1930's and the 1940's during the campus unrest periodof the llite 1960's and early 1970's, and now it has cropped again inthe 1980's.

The old adage, again reported by the Carnegie Foundation, para-phrasing somewhat is let's throw accreditation off the campus andregain control of our own destiny, has been heard for years andyears and years.

It is a typical complaint, usually from university administrators.You do not hear this complaint generally from students or fromfaculty. That seems to me to be the cadre to which the Carnegiereport was suggesting that the control be returned. I am not surethat those criticisms are campuswide.

Specifically, we disagree with the recommendation on page 82that in determining the eligibility of colleges, the Secretary shoulduse regional accreditation as a basis for approval. As previouslypointed out, regional accreditation accounts for only one-third ofthe currently accredited eligible institutions in the country. Werethis recommendation to be implemented without some accompany-ing adjustment somewhere, you would immediately disinfranchisesome 6,000 accredited institutions, and I do not know how manymillions of students involved in those particular institutions.

The further recommendation that the Council on PostsecondaryAccreditation, and not the Secretary, prepare the approved list ofregional associations is probably impractical for some of the samereasons. The recommendation that regional associations shouldhold accounble for areas of special concern hold the campuses re-sponsible for State and Federal agencies and concerns of the court,seems to us to contradict the concept of self-regulation that is pro-moted elsewhere in the Carnegie report.

Last, we ,would deem it an unnecessary delay in due process forCOPA to be a court of last resort to resolve differences betweenmember institutions and their accrediting organizations.

If I may, in conclusion, on Tuesday, if not directly, at least byinference, I am afraid the impression was left with some membersof your committee, Mr. Chairman, specifically Mr. Owens asked thequestion of one witness whether there was any assessment or eval-uation of institutions beyond the fact that they were accredited.

My interpretation, sitting in the audience, to the response to thatwas, well, no, that is it, once you are accredited, you are eligible. Isuggest to you that there are other levels of evaluation, particular-ly with our sector of schools.

Accreditation is just the first ticket-punch, so to speak. There areat least two other ticket punch stops before those eligibility agree-ments are in place and the funds begin to flow. Those responsibil-ities lie within the Department of Education.

Coming back the other way, the Department has on the booksthe statutes, the legal authority to limit, suspend, or terminatethose funds for cause at any time without consulting with accredi-tation or regardless of the accrediting status of an institution.

It is partially because of that, and those numbers of regulations,that we think it is probably impossible and improper for accredit-

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ing ageicies to have to try to monitor all of those during the ac-crediting process.

The other area that seemed to be misunderstood on .Tuesday wasthat accreditation is the only route to eligibility for institutions.There are other routes.

With that, I will conclude.(Prepared statement of James Phillips follows:]

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PREPARED STATEMENT OF JAMES M. PHILLIPS, PH. D., EXECUTIVE DIRECTOR,e' ACCREDITING COMMISSION

SUMMARY OF TESTIMONY

1. The Association of Independent Colleges and Schools is one ofseveral natio%ally recogniied institutional accrediting bodiesin the United States. It is not a "specialized" accreditingbody in the sense of evaluating only explicit program offerings.

2. The national accrediting organizations were not mentioned inthe recent Carnegie Foundation Report "Control of the Campus,"even though they accredit as many or more institutions as dothe regional accrediting bodies.

3. AICS has been recognized by the Commissioner/Secretary ofEducation since 1956, longer than some of the regionalaccrediting bodies.

4. AICS-accredited institutions range in type from those offeringonly short-term programs through those offering graduatedegrees and they range in size from fewer than 200 studentsto as many as 6,000 students.

5. The AICS institutions offer education primarily in business-related areas and ninety percent of the institutions aretax-paying business corporations.

6. The policies, procedures, and criteria by which the AICSinstitutions are evaluated are more similar than dissimilar tothose utilized by regional accrediting bodies.

7. Accreditation should continue to be relied on by the federalgovernment as a threshold criterion to establish eligibilityfor participation in student financial assistance programs.

8. The AICS accrediting body is broadly representative of itstypes of institutions and includes or has input from thegeneral public, business and industry, government, theProfessions. and vocational educators.

9. We oppose in the Carnegie Report the following recommendations:

a. That only regional accreditation be used as a basis forestablishing financial aid eligibility. This will not work.

b. That accrediting bodies should'Or can hold campusesaccountable for areas of special oonairn to state andfederal agencies and the courts.

c. That the Council on Postsecondary Accreditation (COPA)serve as a court of last resort in grievances betweeninstitutions and accrediting. bodies.

10. We want to emphasize, contrary to some recent misstatementof fact, that accreditation is only a threshhold factor inestablishing institutional eligibility. Eligibility assessmentis made at two or more levels beyond accreditation and programparticipation agreements become contracts directly between the .

federal government and institutions. The limitation, suspen-sion, or termination of those eligibility agreements is atthe discretion of the federal government and in no way is tiedto accreditation.

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Mr. Chairman. Members of the Committee. Thank you for this

opportunity to present testimony relative to the Carnegie Foundation

Essay entitled "The Control of the Campus...." I am James Phillips,

Executive Director of the Accrediting Commission of the Association

of Independent Colleges and Schools (AICS). With me are Dr. Robert

S. Kline, Professor at Winthrop College in South Carolina and

Chairman of the Accrediting Commission, and Mr. William C. Clohan,

Jr., partner in the Washington, D.C. law firm of Laessig, Brown,

Hearn and Clohan and legal counsel to the Accrediting Commission.

Prior to entering private practice, Mr. Clohan was Under Secretary

of Education.

INTRODUCTION

We consider the schools and colleges that we represent to be a

significant sector of the postsecondary education community.

We want to emphasize that significance to you inasmuch as the

recent study by the Carnegie Foundation for the Advancement of

Teaching failed to recognize in context national institutional

accrediting bodies such as AICS; rather lumping us for listing

purposes between two very specialized programmatic-type accrediting

bodies.

We have mixed feelings about being ignored in the essay.

On the one hand, we were not included in the criticism contained

in the report toward regional and specialized accrediting bodies.

On the other hand, berng ignored may reflect an historic and,

apparently, continuing lack of acceptance of occupational education

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by the So-called traditional higher education community. I call your

attention to the fact that there are nearly twice as many accredited

occupational institutions as there are regionally accredited `

institutions in the United States. With few minor exceptions, all

of tam accredited occupational institutions are permitted to

participate full); in all student financial assistance programs

authorizd by the Congress.

DESCRIPTION OF

As an association of business schools, the professional ancestry

of AICS may be traced back to the early 1900s. There were an

business or commercial schools in existence long before that.

Today, there are 40 member schools in the Assooiation's Century

Club, denoting that they have been in continuous operation for

more than one hundred years.

The AICS Accrediting Commission has been listed by the Department

of Education as a recognized accrediting body since 1956. Today,

there are 571 schools and colleges and another 174 branch campuses'

accredited by AICS, each of which has been - thoroughly evaluated

by criteria comparable to, and in some areas more rigorous than,

the criteria utilited by the regional accrediting associations.

Our types of institutions range from business or specialized

achoole offering training of up to one year in length to junior

and senior colleges offering recognized associate and baccalaureate

degrees. There are an ()etiolated 400.000 students enrolled in these

institutions.

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Our association and our institutions take pride in the fact that

nearly all graduates available for employment do, in fact, become

employed in occupations, professions, and services (including self-

employment) for which they have been trained.

We note, also, for the benefit of this body and others presently

concerned with precarious nationwide economic conditions that some

ninety percent of the AICS-accredited institutions are tax-paying

business corporations.

These institutions have always provided timely services adapted

to the needs of the student and the community so that the eduational

programs are consistent with .the needs of employers. Because

employers' needs are changing constantly, the institutions

constantly to_meet those needs.

THE AICS ACCREDITING PROCESS

Because the rapid changes in society aro reflected daily in AICS

institutions, we as their accrediting body have to be in tune

with government, business, and industry in order to be sure the

institutions are developing the competencies in students that

the marketplace,expecte.

The AICS Accrediting Commission is broadly representative of each of

our types of institutions, as well as having as members on it three or

four external experts like Chairman Kline from non-AICS-accredited

institutions. Tholt4usually are collegiate schools of business.

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In addition, there is a public member with another to be appointed

.thie year.

There is an outside Advisory Committee to the Commission,

consisting of both traditional and vocational educators,0govern-

ment officials, professional business persons, and one person

who during her tenure has moved from being a.student to being

an active partner in a small business.

The fact that our member institutions differ in some respects

from traditional colleges and universities may account for our

not being mentioned in the Carnegie Foundation Report.

.However, I would like

and criteria by which

to emphasize that the policies, procedures,

our institutions are evaluated are more .

similar than dissimilar to those employed by the regional accrediting

bodies. AICS criteria are applied nationally, not regionally.

We believe this is a strength- -there is unquestioned consistency

of quality standards from California to New York.

As a recognized institutional accrediting organization, we

encourage our institutions to continue self-monitoring and

improvement through the acorediting process in areas such as

student relations, academic programs, faculty qualificatiohs and

in-service training, administrative capability, and supervision

ofstudent financial aid programs.

A word on the area just mentioned--supervision of financial aid.

We believe it important for membeas of this Committee, as well as all

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members of The Congress, to understand, and hopefully accept, the

fact that accrediting bodies simply cannot monitor an institution's

day-to-day compliance with the myriad of federal regulations

associated with the administration of financial aid programs.

We are concerned about and do insist, as part of the accrediting

process, that this area of an institution's operation be capably

administered and supervised. We cannot, just as you cannot,

legislate honesty of individuals. There have been some abuses in

all types of institutions. Accreditation will not stop intentional

circumvention of law or regulations.

Accreditation is and should continue to be relied on an a

threshold requirement for student aid participation. There always

is assessment by the Department beyond accreditation before eligi-

bility is established. Accrediting bodies should not be lade

responsible, however, for auditing each institution's compliance

with those numerous participation regulations.

EDUCATION'COMMUNITY INVOLVEMENT

Our institutions and their personnel hold membership in the

same national educational groups as ao most others--the

American Council on Education, the American Association of

Collegiate Admissions Officers and Registrars, the

American Association of Community and Junior Colleges, the

American Personnel and Guidance Association, the Data

Processing Management Association, the American Vocational

Association, as well ea professional individual disciplinary

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societies ranging from teachers of English and mathematics

to the American Psychological Association. We, as a full

partner in the Council on PostiecondaryEducation (COPA), sit

in the same forums with the regional accreditation groups.

All our institutionsare listed alphabetically by state in the

directory, ACCREDITED INSTITUTIONS OF POSTSECONDARY EDUCATION,

published annually for COPA by the American Council on Education.

We have a waiting list of persons from throughout the

country, both from our institutions and from those accredited

by others, who are anxious to be involved in the AICS accrediting

process. They receive no pay, they sacrifice their valuable time

from their own institutions, and they enjoy being able to ifork

and consult with other institutions around the country.

DENIALZ, WITHDRAWALS, AND LITIGATION

A frequent criticism of accreditation-- repeated again by

attribution in the Carnegie Foundation report--is that

nearly all institutions are accredited, that few ever lose

accreditation, therefore the process is meaningless. This

simply is not true. During recent years AICS has refused

to accredit many institutions because they failed to meet

criteria. We also routinely withdraw accreditation from

institutions that tic longer meet the guidelines. Each

and every such withdrawal is published.

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This rigor of the process has, of course, resulted in

litigation. But during our nearly thirty years of existence,

the AICS Accrediting Commission has never been prevailed

agaiust by a complainant. The courts consistently have

decided that our processes and procedures are equitable,

fair, non-arbitrary and non-capricious, and in the best

interests of the public at large. That is a legal track

record of which we are proud and which, more importantly,

speaks to tne worth of self-regulation as practiced by

our institutions.

THE CARNEGIE REPORT

"The Control of the Campus" is a nice essay -- historically

interesting, well written, and legitimized by an important

philanthropic foundation and an impressive list of panelists.

Most of the criticisms of accreditation in the report are

not new. Historically when the general economy turns down,

accreditation has been criticized. Usually, the severest

criticism comes from within--from institutional admin-

istrators. This was true in the early 1930e, during

the early 1940s, and during the campus unrest years of

the late 1960s. It has emerged again in the 1980s.

The old saw by college and university administrators of,

"throw the rascals out and regain control of our own destinies,"

has beeu voiced again and again over the years. But, only

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by a few of them. One La hard pressed to find such criticism

coming from faculty and students on the campuses- -the very

cadre to which the Carnegie panel suggests control should be

returned.

The report, both in some of its criticisms of institutional

accrediting bodies and in its recommendations to them for

improvement, overlooks a basic important tenet. That is,

accreditation is designed to evaluate educational practices- -

not dictate what those practices are to be. While accrediting

bodies can be the collective guardian of academic quality, and

to a lesser degree, institutional integrity, they cannot cause

institutions to be either good or bad. Institutions, as the

Carnegie Report suggests, must do that for themselves.

!We support some of the recommendations in the report for

improvement or at least change. We know some areas already

are under intensive study by COPA and we are participating in

those efforts.

Some of the recommendations we take exception to as being

unworkable or impractical. Specifically, we disagree with

the recommendation (p. 82) that, in determining the eligibility

of colleges to participate in federal programs, the Secretary

of Education should use regional accreditation as the basis

for approval. As previously pointed out, regional accreditation

accounts for only one-third of the currently accredited and

eligi6le institutions in the country. Was this recommendation

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intended to "deeligibilize" more than 6,000 institutions?

We certainly hope not. We suggest that the social and

political reaction to that from disenfranchised citizens

would overwhelm the Congress.

The further recommendation that COPA,-not the Secretary of

Education, prepare an approved list of regional associations is

impractical for the same reasons.

The recommendation to regional associations that they should

have their own clear standards of academic quality (p. 77) seems

to contradict the overall theme of the report to restore complete

academic control to the campus.

Similarly, the recommendation that regional associations should

hold campuses accountable for areas of special concern to state

and federal agencies and the, courts (p. 77), seems to absolutely

contradict tha concept of self regulation promoted elsewhere

in the report.

Lastly, we would d3em it an unnecessary layer of due procese for

COPA to be a court of last resort to receive appeals and to resolve

conflicts between accrediting bodies and their member institutions.

COPA's role is to insist through its recognition process that all

accrediting bodies have in place and consistently follow an appeals

due process procedure.

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Accreditation has adapted to many educational and

societal changes in the past; is adapting today through

many activities being sponsored by the Council on

Postsecondary Accreditation; wants to be socially acceptable .

while being educationally accountable; and is more than willing

to do its part in what has to be a partnership arrangement

to address both human accomplishments and human

expectations. It should not, however assume or be forced to

assume responsibility in areas for whi h it has no authorization

or institutional agreement.

We at AICS agree that there are far too many externals

affecting our personal and professional lives. 'there

have been far too many social engineers in state houses,

the White House, and the halls of Congress during the

past quarter century. Hut, we permitted them to legislate

and appropriate in the ever rosier expectations of sharing in

the promised commonweal. We at AICS do not apologize for

being a passenger on the bandwagon. At the same time, we

are not so naive as to believe that poetaeaondary education

in this country can or should ever return to the era of Mark

Hopkins and a student on a log. Federal and state bodies have

made it possible for millions of Americans to sit on that

modern-day log. Accrediting bodies have helped to make the

educational experience more meaningful for students. Without

both of the foregoing our society would not be as far along in

its development.

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We at AICS think of ourselves as a full partner in this

endeavor. We have tried to be helpful to The Congress in the

past, and The Congress has been helpful to our institutions and

their students; we have cooperated with the executive branch and

will continue to do so; the courts have upheld the legal appropriate-

ness of what we do and how we do it. We, the Association of Indepen-

dent Colleges and Schools, therefore, proclaim our hard-fought right

to be recognized as a contributing member of the postsecondary

education community in this country.

Thank you for your time and your attention.

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MEMOAccrediting Commission

AICSanonma

Indeaendant Collages and Schwas

Atcraditini Coma luiOnJames M Prbil.ps. Executive Detour

Vcto? K 13,eolnawser, Assstant Executor° Diectof

TO: AICS Member Institutions

FROM: Howard Steed, Chairman, Accrediting Commission

DATE: November 12, 1982

'!SUBJECT: Revised Accrediting Criteria

Enclosed are recent revisions and additions to the Accreditation Standardsadopted by the Commission following consideration of all comment receivedfrom the members.

Also included are two explanatory documents: "Procedures and Guidelinesfor Senior Collegiate Institutions Offering Education at the Graduate Level,"and "Interim Approved Policy Guidelines for Institutional Grant and LoanPrograms." Please note that the latter is still subject to comment frommembers prior toiNovember 30. 1982.

Please review these materials carefully. All institutions are now respon-sible for being in compliance with the criteria as revised.

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GRADUATE CRITERIA ADOPTED IN AUGUST. 1982

CHAPTER 5 Standards for Institutions Offering Educationat the Graduate Level

3.9-100 NATURE OP GRADUATE EDUCATION

NOTE: These statements are more fully eiplained in a separatedocument, "Procedures end Guidelines for Senior CollegiateInstitutions Offering Graduate Programs." Institutionswishing to initiate graduate education should requesta copy of this publication.

Graduate degree programs may be classified in two ways - .research

and professional. The research graduate degree prepares studentsmainly for schOlarly or research activity while the professionalgraduate degree prepares students primarily for specific careersin4usiness and other areas.

The awarding of a seaters degree signifies that, in the judgmentof the faculty, the student has attained specialised competencewhich qualifies the recipient for opportunities and additionalresponsibilities not ordinarily available to the baccalaureate

recipient. To make a graduate program distinctive, a componentdesigned to teach research skills should be included.

Because of the varying student groups served and their specialneeds in terms of flexible instructional approaoheo andscheduling patterns, instructional latitude is encouraged indeveloping innovative graduae programs. The graduate program,however, should not be buil, at the expense of the undergraduateprogram.

Considerations in developing and maintaining a masters programs

a) The program is consistent with the goals end objectives

of the institution.

b) The financial resources required for developing and main-taining the program extend beyond those necessary for anundergraduate program.

c) Quality and depth of instruction requires faculty withadvanced degrees and related professional experience.

"d) The program should enhance the undergraduate program.

e) The program requires the appropriate administrativeexpertise to maintain quality.

f) The program requires strengthening of library resources

on a continuous basis.

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g) The program may require an extension of student services.

3-5-200 ELIGIBLE INSTITUTIONS

a) The institution must be accredited as a senior collegeby the Accrediting Commission of AICS in order foramasters degree program to bs eligible for inclusionwithin the scope of accreditation.

b) The institution must be authorized by the educationallyappropriate state agency, where such authority exists,to legally confer the masters degree.

o) The institution must offer a program which requires aminimum of 30 semester hours, 45 quarter hours, or theequivalent, of masters work with a thesis at the graduatelevel; or 36 semester hours, 54 quarter hours, or theequivalent, of course work at the graduate level.

d) The institution must demonstrate a need in its geographicarea for its proposed program prior to applying for graduatestatus.

3-5-300 PHILOSOPHY AND OBJECTIVES

The objectives of a masters degree program are anextension of the institution's awareness of itsmission to its constituents and to society at large.These objectives are long-range and have a closerelationship to the human, physical, and financialresources available to the institution. They relate

,-to, the student's mastery of a body of subject matterand an understanding of related research and researchmethodology.

While program objectives are usually stated in generalterms, course objectives should be more precise. anddirectly related to the learning outcomes.

Continuous internal evaluation of program objectives isessential for providing viable graduate education. Theattainment of the institution's objectives shall bemeasured by the productivity and professional performanceof its graduates as well as by evaluation of its programsby students and alumni.

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3-5-400 EDUCATIONAL ACTIVITY

3-5-401 Graduate faculty must be directly involved in thedevelopment and codification of graduate program policiesAnd prooedures and in the development and modification ofcurricula.

The masters degree program is a direct outgrowth of theinstitution's statement of philosophy and objectives ofgraduate education and should be structured on a foundationof subject matter from the functional area. Normally,the masters degree program is the equivalent of onecalendar year of full-time graduate study and inoludesthe following oosponent41

a) An understanding of the subject matter with sufficientbreadth and depth, at the advanced level, that permitsthe students to further their profession and makesignificant contributions to society by addressingtechnological, social, economic, and political issuesand problems.

b) An understanding of research and research methodologythat contributes to the student's intellectual inquiryand sense of creative independence.

c) An evaluation of the knowledge, skills, and competenciesas a means of certifying the student's ability tointegrate the bodies of subject matter in (a) and (b).

d) A learning environment that is conducive to theacquisition of knowledges, skills, and competencies atthe graduate level.

3.5.500 ORGANIZATION, ADMINISTRATION, AND CONTROL

3-5-501 The responsibility for developing, modifying, and main-taining the graduate program shall be performed by a qualifieddesignated committee. Administration of the graduate programshall be performed by a qualifiefildividual with appropriateadministrative and educational background and experience for thedirection of a graduate program. The duties of this individualmay be full. or part -tics with adequate staff support.

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3-5-600 FACULTY

3-5-601 The institution shall have an adequate and competentfaculty working under conditions that encourage their bestefforts. The size of the faculty shall be appropriate forthe graduate enrollment. All masters program faculty shouldhave an appropriate graduate degree with sufficient numberpossessing a terminal degree. Professional certification isnot a substitute fcr a terming'. degree. At least one-half ofthe graduate level courses are to be taught by full-time facultyand at least one-half of the graduate level courses shall betaught by faculty possessing terminal degrees.

3-5-602 In judging competence of faculty, consideration shallbe given to the academic preparation and experience of'eachinstructor. During any academic term, a faculty member shallnot be assigned to teach in more than three fields of instructionand preferably in not more than two fields. Instructorsshall be assigned in terms of their major and minor areasof academic preparation and related experience. The totalteaching load of faculty members teaching one or moregraduate courses shall not exceed twelve credit hours perterm.

3-5-603 The institution should present evidence of astable graduate faculty; stability is particularly importantfor those programs which contain courses of a sequentialnature. The institution should also encourage graduatefaculty members to engage in scholarly research and topublish in professional journals.

3-5-700 TH3 LIBRARY AND INSTRUCTIONAL MATERIALS

3-5-701 Institutions offering graduate programa shallprovide access to substantially different library resourcesin terms of their depth and breadth than those requiredfor baccalaureate degree programs.

These resources shall include bibliographic and monographicreferences, major professional journals and reference services,and research and methodology materials. The breadth anddepth of the accessible library holdings shall be such as toexceed the requirements of the average student in order toencourage intellectual development of superior students andto enrich the professional development of the faculty.A librarian with special qualifications to aid in researchstudy shall supervise the library.

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3-5-702 Library acquisitions are the joint responsibilityof the faculty and library staff, with the greater amountof input emanating from the faculty. Also, it is thefaculty's responsibility to inspire, motivate, and directstudent usage of the library resources. The ultimatetest of the library's adequacy is determined by thesztent to which its resources support all the courses offeredby the institution.

3-5-800 ADMISSIONS

3-5-861 Admission to a masters program is based on thepossession of a baccalaureate degree from an institutionaccredited by an institutional

accrediting agency listed bythe United States Secretary of Education or an institutionalagency recognized by the Council on Postsecondary Accreditation.

3-5402 In evaluating applicants, appropriate techniquesshould be used to determine whether they have the academicqualifications to benefit from graduate study.

3 -5403 Transfer of credit for appropriate graduate levelcourse work from another institution may be granted accordingto the policy established by the institution. (Institutions areencouraged to follow the guidelines on transfer and award ofacademic credit developed by the Council on PostsecondaryAccreditation, the American Council on Education, and theAmerican Association of Collegiate Registrars and AdmissionsOfficers.)

3-5-804 Admissions procedures, transfer policies, andrequirements for graduation shall be stated in the collegecatalog and shall be consistent with the overall philosophyand objectives of the institution.

3-5-900 PUBLICATIONS

3-5-901 There shall be a separate section in the institution'scatalog describing the masters degree program requirements,regulations, and course descriptions.

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Section 1- 3- 103 -- Senior Colleges

Because graduate criteria were adopted, the definition of senior

colleges was expanded to include graduate program offerings within

the scope of the institution's accreditation and will read as follows:

1-3-103--S;4or'Colleges

A senior college is a four-year collegiate institution

devoted predominantly or substantially to education

for business at the collegiate level. Such institutions

offer programs of tour academic years.in length

leading to an appropriate baccalaureate degree, and

may be responsive to community needs by also offering

occupational, specialised adult, remedial, or

continuing education programs. Senior colleges may

also offer programs leading to a graduate degree.

Su

00OOO,

1- 4- 101 - -Non -Main Campus Educational Activities

A revision to 1-4-101 (a) Branch Campus is editorial in nature and

technically clears up what in practice has been an inconsistency with

another section of the Standards. The change permits without conflict

an institution to operate and the Commission to evaluate a branch

campus that is single-purpose and, perhaps, all technical.

The change deletes the former references that a branch campus has to

meet the eligibility requirement that it will be able to seek accred-

itation in its own right which would have required it to have been

predominantly business in nature from its inception.

That particular eligibility requitement still will have to be met by

the branch before it can be evaluated by the Commission to be a

free- standing institution following two years of operation.

The new language reads as follows:

(a) Branch pampus. A branch campus could be

distinguished by such characteristics as: offering

a complete program leading to an occupational objective

or academic credential; exhibiting the ability, except

for the remoteness of ownership and control, to

meet the requirements of the evaluative criteria in

Title III of the Standards; and having a significant

amount of local responeiblity for administrative control

and academic affairs.

175

3-1-421--Scholarships, Institutional Grants, Institutional Loans,and Financial Aid

This section replaces existing 3-1-421Scholarships and Financial Aid.It clarifies how the Commission will treat this area of an institution'sactivities. With many institutions wanting to offer some institutionalfinancial aid to deserving students in the form of grants and loansrather than scholarzhips, the proposal will permit that within theparameters set forth. Institutions are also referred to the interimApproved Policy Guidelines adopted by the Commission concerning accept-able characteristics for such institutional programs.

(a) With the prior review and approval of the Commission, institutionsmay participate in scholarship, institutional grant, and insti-tutional loan programs which acceptably reflect the dignity andintegrity of she institution so long as the ethical application ofthose programa falls within the publicly and generally acceptedmeaning of the terms "scholariphip," "grant," and "loan."

(b) scholarship, institutional grant, and institutional loan programsshall be printed in the current catalog of the institution withfull disclosure of the terms, conditions, souece, applicationprocedures, deadline dates, basis for selections, number (scholar-ship only), maximum and minimum awards (scholarships and grantsonly), and aggregate award volume (scholarships and grants on1O.

(o) Financial aid (such as grants, loans and work-study programssupported by outside sources such as private organizations or stateand federal governments and supervised by an institution) may beoffered so long as they are administered within the guidelinesestablished by the funding source. It is the responsibility ofthe institution to clearly identify, in all its publications and byall its actions, the distinction between the publicly and generallyaccepted meanings Of the terms "scholarship," "grant," "loan," and"financial aid."

0 * *

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PROCEDURES AND GUIDELINES FOR SENIOR COLLEGIATEINSTITUTIONS OFFERING EDUCATION

AT THE GRADUATE LEVEL

These procedures and guidelines have,been developed to assist thesenior collegiate institution in prepiring for graduate programs tobe included within the scope of accreditation of the institution.Attention is given to those areas of importance which focus on thequality and relevance of the program under review. The institutionshould maintain close consultation with the Commission staff whileundergoing the accreditation process.

PROCEDURES

The institution must notify the Executive Director of the Commissionat least six months prior to initiating a graduate program. Followingnotification, the institution must prepare and submit for review bythe Commission a report on the graduate programs. (See GUIDELINESof this publication.)

Upon acceptance of the graduate program report, the Commission maygrant an interim inclusion within the scope of the institution'saccreditation for a period not to extend beyond two years. Duringthe interim inclusion, a follow-up evaluation will be scheduled.This evaluation will assist the Commission in ascertaining the overallquality and effectiveness of the graduate program while it is inoperation. When final approval is given by the Commission, the graduateprogram will be included within the scope of accreditation of theinstitution and, thereafter, be reevaluated at the time of thenormal accreditation schedule of the institution.

GUIDELINES

The following requirements have been established by the Commissionand must be addressed in the graduate program report.

1. Statement of Rationale for Offering the Graduate Program.

This statement should explain the relevance of thegraduate program to the professional dsvelopmsntand awareness of the graduate student as well asthe impact the program may have on the institutionand the community, including any market surveysconducted.

2. Curriculums for All Graduate Programs.

The copy of each graduate program curriculum must includes

a. Objectives of the program;

b. Program outline;

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c. Listing of all courses showing credit allowed for each;

d. Thesis requirements; and

e. Total amount of credits required for completion ofthe program.

3. Evidence of State Authorization.

Documented evidence must include specific state authority,unless the law is silent, for the awarding of graduatedegrees by the institution.

4. Information on the Person(s) Responsible for Administeringthe Graduate Program.

Documentation supporting the qualifications (educationalbackground and experience) of the administrator and theadministrative staff must be submitted.

5. Information on Faculty.

The following items must be included for all full-time andpart-time graduate faculty:

a. Official transcripts, including evidence of degree(s)obtained;

b. Experience, other than academic, evidencing qualificationsto teach at the graduate level; and

o. Contractual arrangements, including credit hour teachingrequirements.

6. Library Development Plan.

The institution should indicate what measures are being takento develop or expand its library reeourcea to meet graduate-level criteria.

L."Z .1. so

181.

178

MEMOAccrediting Commission

AIICSAneetedso .e

Indepthditilt Colleges and SchoolsAccrediting Commission

M PP, i.r5 Eaecuhve D.secloIv.00t A- C' ASSSts's EsEtubse Ddectof

TO: AII1S Accredited Institetila., and Interested Parties

FROM: Accrediting "omission

DATE: September 16, 1182

SUBJECT: Interim Approved Policy Guidelines for InstitutionalGrant and Loan Programs

The :omission reeognizes twit acereiited inatitutions may desire fromtime to time to offer programs of institutional financial assistance

to students. The 7,ommisaion also has >a responsibility to its variouspdblids to set appropriate guidelines for such prozrana in order to

insure their legitimacy. Accordingly, any institution deairing tooffer any institutional grant or loan program will be required to sub-mit the details of any such program to the Commission for prior review.

In reviewing proposed programs of this type, the Commission will con-sider the characteristics listed below. These characteristics are not

listed in any priority order. Any institution whose grant or loan

program is not in accordance with any or all of these characteristicsmay be subject to a directive by the Immiaaion to show cause why itsprogram is acceptatle and why its grant of accreditation should not besuspended, revoked or otherwise conditioned. The greater the number ofthese characteristics evident in an institution's grant or loan program,the greater the presumption of acceptability. However, the Commission

will review each institutional grant or loan program in its entiretyand not based solely on its individual parts.

1. The grants or loans are made from identifiable and segregatedfunds of the institution.

2. The per2entage of students re4eiving institutional grants orloans, an compared to the overall student population of the

institution. is not Inordinately high.

3. The total amount for institutional grants is publicly andclearly identified prior to the beginning of the academicyear or term.

4. The amount of the grant or loan varies according to thetosivtioal financial need of each student receiving the

assistance.

5. Tho amount of the grant or loan is not based solely on thedifference between the tuition charged and the amount of

federal or state financial aid received.

182

+110 'A Srs! Wash -y.s, 7 r 20036 202 669.2460

J k) 4

179

6. The tuition charged reasonably and closely repreaents thecost to the institution of the coursework provided and doesnot significantly vary in amount from a similar or samecourse provided in another certificate or degree program.

7. The amount of tuition retained as non-refundable by theinstitution from those students who drop out prior to theend of the academic term or period is proportionatelyallocated between the institutional grants or loans and thefederal and state financial aid received.

i 8. The collection of institutional loans is pursued in anaggressive and systematic manner, based on sound businesspractices, for all student borrowers.

9. The type and amount of institutional aid provided is deter-mined by an independent selection or review panel.

10. Any specialized or contractual programs, for which an insti-tutional grant or loan is utilized, are not open to thegeneral public.

These Interim Approved Policy Guidelines are effective immediately andwill remain in effect pending a further review by the Commiasion at itsDecember, 1982 meeting. Any accredited institution or interestedpersons or parties desiring to comment on these guidelines are encour-aged to do so. Any comments should be addressed to the Commission andshould be received in the Washington office prior to November 30, 1982.

ar

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Mr. SIMON. Thank you. If' I may just follow up, I did not quiteunderstand. You said there are two other ticket punches. What arethe two other ticket punches you are referring to?

Mr. PHILLIPS. The institutions, once accreditation is achieved byan institution, that institution must then take that fact, first of ajl,to the eligibility section in the Department, where it gets evaluat-ed, and then specific program participation agreements have to becarried out with another section within the Department so thatuntil those three places have been assured, until approval fromthose three have been assured, the eligibility really has not beenestablished.

Mr. SIMON. Does your association, which; as you point out, repre-sents two-thirds of the accrediting institutions, you have anydoyou work with the Council on Postsecondary Accreditation at all?

Mr. PHILLIPS. Yes; very closely. We were a charter member ofthat organization.

Mr. SIMON. Does the Carnegie recommendation suggesting thatthey hav,e, in fact, assumed much of the 'work the Secretary nowdoes, does that make sense to you or does it not?

Mr. PHILLIPS. I think there is some middle ground there. Theproblem is that, and again, it came out in the testimony on Tues-day, the Secretary recognizes and lists so many more accreditingbodies than are presently recognized or have been evaluated byCOP,. I do not know how you resolve that dilemma if that shouldoccur.

I think, as Dr. Manning indicated, there are so many intricaciesin trying to untangle some of these things, ideally maybe thatcould be done at some point in the future. But I do not think thatit is reasonable to believe that it could be done very quickly.

Mr. SIMON. Dr. Manning and Dr. Sweet, my apologies for notbeing here when you testified. I may be asking you to go over, infact, I guess I am asking you to go over some testimony you havealready offered.

If either of you suddenly became the member of this subcommit-tee or Secretary of Education and you could just wave a magicwand and you could do three things to improve the accreditationprocess, what would those three things be?

Mr. MANNING. Gordon, you are older than I am. [Laughter.]Well, Mr. Chairman, one of the principles that I try to guide my

life by is, if it works, do not fix it. I think one of the points that needsto be emphasized here is that over the 30 years that the presentsystem has been in place and has evolved, it has worked really quitewell for the purposes for which it was intended.

It was not intended as an arrangement of having accreditingagencies or other persons not directly connected with the FederalGovernment to monitor the compliance of institutions with specificregulations or requirements. It was intended to provide a basic as-surance to the Federal Government that its funds were being ex-pended in or for the benefit of institutions of reasonable and ac-ceptable quality. That has been the case, by and large, over 30years. There have been individual exceptions, but individual excep-tions will occur in any kind of human enterprise.

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The actions that the Secretary takes in examining the accredit-ing agencies, I think, are proper. The only suggestion that I wouldmake is one that appears in my testimony, that I think a degree ofcooperation which is possible within the framework of existing stat-utes between COPA, Council on Postsecondary Accreditation, andthe Secretary, could reduce the administrative burden on the ac-crediting organizations.

But I think no basic change in the statute is necessary, or indeeddesirable.

Gordon.Mr. SWEET. I think over the years that we have regretted but we

have certainly cooperated and participated in the use of regionalaccrediting for eligibility for Federal funding. I think this hasmade accreditation sometimes a little difficult in dealing with insti-tutions, although I believe that we are now so set into this routethat there is no way to change it.

In my span of experience, earlier it was somewhat of a struggleat times to give advance recognition to institutions and so on with-out really going through some of the process that we wanted to be-cause we regretted that the institution could not get the funds thatmight be available. It has presented some difficulties.

I think that is the purposeful one. The other is that we alwayscan use more money and more people to do a bigger job. I believethat is it.

Mr. SIMON. OK. Then one final question if I can address this tothe two of you and also to Dr. Carpenter, who has the practical ex-perience at an institution. Should the Department be involved inaccrediting the engineers association and the journalism associ-ation and all of the umpteen various groups that we do, and specifi-cally to you, Dr. Carpenter, does that present a problem when youare trying to run Memphis State University?

Incidentally, you are at Memphis State, you are getting close tomy district. My district is deep southern Illinois. I am a heck of alot closer to you than I am to Chicago.

Mr. CARPENTER. Well, earlier when there was a reference to aproblem, I assume it came out, perhaps journalism or something ofthat nature, specialized accreditation, I will have to admit that wedo have some problems with those areas. I am not sure, though,that we should attempt to solve them through the Federal Govern-ment. My feeling is that except in rare instances, the presidents ofthe institutions themselves should take this on as a task and re-solve it.

Mr. SIMON. If I may press, at the present time, the Federal Gov-ernment is involved to the extent that we recognize these variousassociations. They come to you and say, you know, you have to dothis, that or the other thing or you are going to lose your accredita-tion.

Mr. CARPENTER. Well, I will cite as an example the military, forinstance, will not commission a nurse -tio has not graduated froman LN-accredited program. That sort of thing creates some prob-lems with us because we sometimes disagree, and I will not selectNLN, but we sometimes disagree with the specific criteria whichwe believe infringes on the autonomy. of the institution unnecessar-ily.

22-141 O-M4 --12

182

We would hope, though, that those in the profession in nursingor in law or in any of these others would understand the problemand work with us. I have no objection to the Federal Governmentrecognizing that, but there is something in between those two thatneeds some correction in our opinion.

Mr. SIMON. Any comments either of you wish to make?Mr. MANNING. I think, Mr. Chairman, that if the Federal Gov-

ernment has a program or process of recognizing or listing accred-iting bodies, as it does, and for good reasons, then it is essentiallyimpossible for it to exclude from that process accrediting bodiesthat seek to be recognized, because one cannot claim that you couldrecognize only the bodies whose accreditation is necessary becausethe accreditation may not be necessary until after they are recog-nized.

Essentially, you would have to have an open door. I do not thinkthere is any way of getting around that. Insofar as this impingesupon the institutions, I think this comes back to the theme of theCarnegie Foundation report, the institutions themselves need totake responsibility. I speak as a person who has been a presidentand a dean and a vice president in several institutions.

There iS no cachet provided by the recognition of the S retaryof Education that prevents any institution from saying to a special-ized agency or to an institutional agency, we do not wish to be con-nected with you.

Indeed, within the last year, two major universities have told oneof the specialized agencies, we no longer wish to have our programaccredited by you, goodby. That agency is recognized by the Secre-tary and the Secretary's listing of that agency does not present anybarrier or problem to the institutions if they pull up their socksand do something.

Mr. SIMON. All right. I guess that is a good practical phrase onwhich to end that testimony.

Mr. Coleman.Mr. COLEMAN. I was wondering if each of the three of you 'could

briefly outline what happens if you receive complaints by eitherstudents or the general public about the academic quality of an in-stitution that you have accredited in the past. How do you handlethat, and do you wait until the next 5 or 10 years go by before youdo something about it ? Just briefly, how do you handle somethinglike that?

Mr. MANNING. Our complaint procedure runs along these lines.We first of all have certain criteria with respect to whether thecomplaint is valid. It must be written, it must be signed, the com-plainer must know that we will share it with the institution. Occa-sionally, we get, well, not occasionally, I guess about half the timewe get anonymous complaints where the complainers says, well, Ido not feel strongly enough to do anything, so that passes out.

When we get a valid complaint, the first thing we do is to shareit immediately with the chief executive officer of the institution forthe comments of the institution on the complaint.

Based upon that response so that we have the complaint and theinstitution's response to it, the staff can then make a judgment asto whether further examination is necessary, whether the com-plaint has been resolved, whether the complaint is valid.

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If further examination is necessary, we will send a team. We donot wait for the next 5 years. Interestingly enough, most of thecomplaints that we get turn out to deal with either individual prob-lems, that is, someone feels they have not been properly paid forservices rendered, which falls outside our scope of activity, or theyare complaints where something has happened deep down insidethe institution and as soon as the president finds out about it,things are resolved and the complaint is solved without further at-tention.

Mr. SWEET. I think this is probably the procedure of all the re-gional associations. We do deal with those immediately, particular-ly through ; chief executive officer. Sometimes I much preferjust to throe. them in the wastebasket. One I received yesterdaywas from a parent, who obviously knows much more about comput-ers than his daughter's instructor does, and so he feels that thedaughter is not getting proper instruction in the computer becauseshe is not learning all the things that he knows.

This is a sort of a complicated one, because I gather that he is arather important person somewhere, some engineering firm, I sup-pose, but we/will take that up with the president and look into it.

Mr. COLEMAN. Dr. Phillips.Mr. PHILLIPS. Our procedure is similar, Mr. Coleman. No com-

plaint goes unanswered longer than 24 hours by my directive tostaff. The institution is informed of the complaint, asked to respondwithin 10 days to us. We try to resolve all complaints from eitherstudents, parents, faculty at the institutions, by the way, or otherinstitutions with a 30-day period to the satisfaction of all parties.

Mr. COLEMAN. I note in your testimony that you say that youhave never lost a legal case over accreditation. Is litigation a fre-quent byproduct of your review process for the others, and haveyou also a 100-percent track record in that? If not, what happenswhen somebody feels strong enough to file a lawsuit against you? Icannot imagine that that does not color the relationship for sometime down the road.

How do you handle that?Mr. SWEET. It would be colorful, there is no doubt about that.Mr. COLEMAN. Colorful.Mr. SWEET. But we find that the cost of the due process proce-

dures, the appeals procedures that all of us have in the regionalassociations, really pretty well take care of this because they cankeep right on moving up and if the last resort would be to go to thecourts, and at the present time, we, even though we have beenthreatened, it has not happened. We haVe a long history of accredi-tation in the southern region.

Mr. COLEMAN. Dr. Manning.Mr. MANNING. Yes; our situation, I think, is similar. We were

last sued in the late 1960's by Parsons College when we revokedaccreditation from Parsons College. Before that, it was in the1930's when we were sued by the State of North Dakota for revok-ing the accreditation of North Dakota State University or StateCollege, as it was then. That is a celebrated landmark case knownas the Langer case, after the former Governor. But in the mean-time, I think our own internal procedures lif; ye strongly improved,as Dr. Sweet has indicated, and this problem is not a serious one.

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Mr. SWEET. We have had a couple of Governors who did not wantto sue us, they just wanted to kick us out of the State.

Mr. SIMON. How do you set your fees to institutions that youreview? Do they pay you a certain amount of money? Is it a mem-bership fee? How do you handle that?

Mr. MANNING. We have two sources of charges to the memberinstitutions. One is an annual membership dues. We are a member-ship organization, incorporated in the State of Illinois, and themembers are the institutions. So, there are annual membershipfees.

Mr. COLEMAN. Is that set by size of enrollment?Mr. MANNING. Yes; in our case, it is.Mr. COLEMAN. What would be typical for a large and for a small

school?Mr. MANNING. The smallest is an institution below 500 persons,

the membership annual dues at this point is $360. For the largestinstitution above 10,000, it is, I believe, $1,310. These are small,they have increased by 5 percent since 1975. They have not movedstrongly there.

We also, however, charge an evaluation fee. This is a flat fee, de-pending upon the number of days the team is present in the insti-tution and the size of the team. This is looked at and adjusted an-nually so that over the whole group of evaluations, the evaluationfees pay for these direct costs of the evaluation.

This means that the institution knows in advance, since it is aflat fee, what it will be, and it also means that the commission doesnot profit from this activity.

Mr. COLEMAN. Typically, what kind of ballpark figures would yougive, is that possible?

Mr. MANNING. Yes; I can say that in general it would run about$2,500 for a typical team for a 3-day visit.

Mr. COLEMAN. And that occurs in what intervals on a campus?Mr. MANNING. In our situation, it depends upon the institution.

We must reevaluate an initially accredited institution within 5years. If we reevaluated it, it must be reevaluated again within 10.Actually the time interval is set individually for each institution,based upon a judgment made through the previous evaluation ofthe rate at which change is occurring or should occur in the insti-tution. Rapidly changing institutions are evaluated more frequent-ly.

A few institutions, therefore, are visited as frequently as everyother year, all candidate institutions are, for example. And large,stable institutions, such as the University of Illinois, Champaign-Urbana or Nebraska are visited once every 10 years.

On the average, we are now visiting our institutions about every6 years, more than half are on the less-than-10-year review cycle.

Mr. COLEMAN. Are all of you set up not to make a profit; in otherwords, you are a not-for-profit organization that is chartered thatway?

Mr. MANNING. We are chartered that way, yes.Mr. COLEMAN. And you have a tax-exempt status?Mr. MANNING. Yes; we are a 501(0(3) organization, incorporated

in Illinois, and as one of our requirements, a full set of audited fi-

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nancial statements must be published to all the members, indeed tothe public, in our journal each year.

Mr. COLEMAN. I thank you. I said the other day that this is arather mystical area of higher education I am glad to see some ofthe mystics come forward. I had some calls made back to my dis-trict to see if there were some questions that some campus admin-istrators might like to have asked of you this morning and I wassurprised that the response was maybe in the past they may havehad some questions, but through internal procedural changes, thatthey were delighted and happy, very much so, with Dr. Manning'sorganization, where I come from.

At least you have satisfied your constituency there.Mr. MANNING. That is important.Mr. COLEMAN. I have been very impressed with all of your testi-

mony and thank you very much.Mr. SIMON. I thank you, too. I join Tom, it has been an educa-

tional process for me just to learn a little bit more about how all ofthis takes place. We appreciate it very much.

Dr. Phillips, if we want to complain about your general counsel,.do we do that to you, personally? [Laughter.]

Mr. COLEMAN. Wait until he loses a case.Mr. SIMON. OK..Mr. PHILLIPS. Our new general counsel has not been tested yet.Mr. SIMON. Let me also invite any accrediting associations that

have not had the opportunity to present oral testimony, we wouldbe happy to have any testimony they might wish to submit enteredinto the record. They should submit that fairly soon if you want itentered into the record.

Again, we appreciate the contributions that all of the witnesseshave made, and will be asking follow up questions for the record.

The hearing stands adjourned.[Whereupon, at 11 a.m., the subcommittee was adjourned, to re-

convene subject to the call of the Chair.][Additional materials submitted for inclusion in the record

follow:]

186

AMERICAN COUNCIL ON EDUCATION ,Office of The President

MARS

March 3, 1983

Mr. Paul Simon, ChairmanCongress of the United StatesHouse of RepresentativesCommittee on Education and LaborSubcommittee on Postsecondary Education320 Cannon House Office BuildingWashington, D.C. 20515

Dear Paul:

In response to your request of February 22, 1983, I am pleased to enclosemy response to the list of questions accompanying your letter.

I appreciated the opportunity to participate in the hearings and to submitthese additional responses for the record.

JUP/gtk

Cor Jelly,

W. Peltason

One Dopov ("de Washington DC 200361193President (202) 833.4710 Mee President (202) 833.4712

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Responses to Questions SubmittedBy the House Subcommittee on Postsecondary Education

Reference: Subcommittee Hearings

on AccreditationQuestion 1.

You state that Federal olic and rocedures have alread " one a ste too far

in bolsterin the role of specialized accreditin a encies." What ro e do yousee, any for spec a zed accre t

that COPA should be responsible for natilrArricognitiOnoftheseagencies;ifas iFigiTized agency receives COPA's approval, why is that different fromDepartmental approval?

I see a very limited role for specialized accrediting agencies in the

establishment of eligibility for federal funds. Federal funds go to the

institution not to the specialized unit or program; and the statutory

references to accreditation in almost every instance are to institutional

accreditation. Status granted by a specialized agency should only be used to

establish eligibility for federal funds when it is the only accreditation held

by a freestanding special purpose institution.

The question of COPA approval versus Department approval for specialized

accrediting agencies goes to the heart of self-regulation initiatives of higher

education. COPA is higher education's agency to foster and assure good

practices in accreditation. The COPA recognition process is the basis for

colleges imposing voluntary sanctions against agencies failing to comply with

the code of good accrediting practice established by the academic community.

The Department's list serves no such purpose. The Department's list was

established only as a listing of accrediting agencies to be used, in determining

institutional eligibility, for certain federal funds.

Under present policy and practice, a specialized agency can attain

recognition by the Department without first gaining the approval of COPA. This

undercuts the effectiveness of higher education's self-regulation efforts.

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188

Holding "national recognition," a concept imbedded in the recognition criteria

of the Department, should mean having formally been recognized by academic

peers (COPA recognition) if self-regulation efforts are to be supported and to

succeed. The mere fact that the Department's recognition process is a

government activity makes it markedly different from self-regulation

initiatives even though academics are used in an advisory capacity.

Questions 2 and 3

While it is clear from your testimony that you favor nongovernmentalaccreditation of colle es and universities it fi not clear whether ou fullsupport the edera government s wit rawing tote y rom approve oaccrediting agencies. Do you feel that CPA should have the final sayapproving accrediting agencies? In what ways do you feel that the current

roval of is

ditTifileaaliiiiic community? Doyou have any suggestions for changing the system--other than totallyeliminating the Federal role--which might improve the system.

Certainly I believe, for reasons just stated above, that COPA should have

the principal and initial say and no agency should receive Department

recognition without first having COPA approval. Moreover, as I view the

present recognition processes now operated by COPA and the Department, they are

essentially the same. The results have been different because some agencies

hive sought and obtained Department approval without first seeking and

obtaining COPA approval. Therefore, the Department's list is more inclusive

than COPA's. In keeping with the principles stated above, the Department's44

list should not contain any agency not first approved by COPA.

. Moreover, few extra assurances relative to the capabilities of accrediting,

agencies are provided by the Department's recognition procedures that are not

provided through COPA's list of recognized agencies. If it is good public -

policy (we strongly support the premise that it is) for the federal government,

to rely on nongovernmental accreditation tp establish the educational quality

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Or'

1.8

MICROCOPY RESOLUTION TEST CHARTNATIONAL BUREAU OF STANDARDS

STANDARD REFERENCE MATERIAL 1010a(ANSI and ISO TEST CHART No 2)

t189

of institutions seeking eligibility for federal funds, I believe that it

follows thik,it is good ptiblic policy for the federal government to mainly rely

on nongovernmental recognition procedures to determine which agencies 'should be

used to establish eligibility.

As stated above, the principal problems with Federal governmental approval

of accrediting agencies is that it results in some agencies being recognized

that do not have COPA approval. This factor provides some leverage that ,

specialized agencies use to undercut our own COPA procedures. These problems

could be eliminaLed by some modifications in the Federal role.

First, the federal criteria for recognition should be changed to require

COPA recognition as a condition of being included in the Department's list.

Second, the Department should limit its recognition process to special ,

requirements not covered by the COPA recognition process.

There may be rare instances when there should be exceptions to the abovp.

If so, they should be made with the 'advice of the Dcpartment's Advisory'''

Committee and with the consultation and concurrence of COPA.

J. W. Peltason, PresidentAmerican Council on EducationMarch 3, 1983

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SOyTfIERN ASSOCIATION OF COLLEGES AND SCHOOLS

795 Peachtree Street, tv.E Atlanta. Georgia 30365,

Phone 897-6100 Area Code 404

March 4, 1983

Mr. Paul SimonSubcommittee on Postsecondary EducationCommittee on Education and LaborU. S. House of Representatives320 Cannon House Office BuildingWashington, D. C. 20515,

Dear Mr. Simon:

MAR I 0 1983

Thank you for your letter of February 23, 1983 in which you,invited me to respond to several questions concerningaccreditation. Enclosed are my responses to the questions

you have asked.

I appreciate this opportunity and hope you will contact meagain if further information is needed.

GWS/ml.

Enclosure

Sincerely,'

:C. V

Gordon W. SweetExecutive DirectorCommission on Colleges

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SOUTI.ERN ASSOCIATION OF COLLPGES ANI) SCHOOLS295 Peathoee Street. r E Althinw. Georg i 30365

Phone 897.6100 Area Code 404

March 4, 1983

1. Do you feel that special program accreditation (excluding professional schools)is necessary or appropriate even though'you association has already-accreditedthe institution? -

It has long been our policy that it is an institution's prerogativ'e todetermine the extent to which it involves itself in the review ofprograms by specialized accrediting agencies. Many of our institutions'presidents would agree, however, that thpre have been problems with spe-cialized accrediting agencies. The requests of these agencies are oftenconsidered unreasonable and as undermining institutional autonomy.Programs With specialized accrediting, because of their support by theaccrediting agency, are often able to compete Tore vigorously for limitedinstitutional resources, thus affecting the overall academic balance ofthe institution. The numerous accrediting teamv,,with the concomitantexpenditure of staff time and funds for self-studies, make it difficultfdr institutions, especially when funding 4s 4ight.

In our evaluations of institutions according to our standards we give at-tentiorrto broad areas of curricula and the resources and faculty availablefor academic programs. In instances where an institution either does nothave program accreditation, or has not had a recent committee visit in thespecialized program area (nursing, social work, allied health, engineering,etc.) we will usually put evaluators on the team to look at those areas inlight of our standards. Institutions may, and often do, schedule special-ized Accrediting visits to coincide with the visit of our regionalaccrediting team,

Whether regional accreditation would suffice or is appropriate in lieu ofprogram accreditation is a question which ultimately and appropriatelyneeds to be answered by our accredited institutions,.

2. Dr. Ambach testified that he feels state accreditation is a viable activity.Do you believe there is ever a need for the states to establish approvalprocesses?

There may exist a need for states to establish state approval mechanismsin cases where state funds are provided to institutions which are notaccredited by a recognized accrediting agency. State involvement in regu-lation of accredited institutions presents the possibility of politically

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motivated erosion of institutional autonomy. Not only would a system ofstate regulation or accreditation be a threat to institutional autonomy,

'but it would introduce another layer of evaluation into the process ofassuring academic quality. Also, higher education is increasingly mobile,operating in many instances across state boundaries. Regional and nationalaccrediting, being nongovernmental and able to conduct e.aluations freedfrom local concerns and biases may be in a particularly favorable positionto deal with this mobility.

3. Can you give us some exampleS of Federal criteria for accrediting agenciesthat you object to?

Regional accrediting commissions of higher education have traditionally beenconcerned with maintaining standards of quality in accredited institutionsand with promoting institutional self-improvement. Congress recognized the

4' Validity of this function in 195? when, the Commissioner of Education wasauthorized by the KoreawWar G.I. Bill to list the regionals and othernationally recognized accrediting associations that were determined to bereliable authority as to the quality of training offeredby an educationalinstitution. This authorization assumed that there existed such privateassociations and that reliance on them would lessen the threat of federalcontrol of education. This legislation was intended to avoid the directregulation of educational institutions, with the assumption that the federalgovernment would not do this indirectly by regulating the 'accreditingassociations. This was the situation from 1952 to 1968: the Commissionerconsulted advisory groups of educators, some of which were drawn from theacccediting ceminunityt in making determinations as to which accreditingasse*ations had gained acceptance in the higher education community andShould be Waced on the Commissioner's list.

The initial 1952 criteria for recognition, developed in consultation withthe higher education community, were not revised until 1969. This revision,

and others which have followed, have expanded inappropriately upon theprocedures that accrediting agencies must employ, even to the extent ofspecifying the manner in which an institution should conduct its owh self-study.

The criteria have also required accrediting agencies to "foster ethicalPractice" such as equitable student tuition refunds and nondiscriminatorypractices in admissions and employment within acrredited institutions.These types of provisions are an attempt to regulate institutions throughaccrediting agencies and move accrediting associations away from their tra-ditional role into that of law enforcement agencies. In the 1970's it wasproposed, in addition, that the Commissioner make a determination that an

. accrediting association was reliable authority as to the "probity" of itsAccredited institutions. Fortunately, this was not incorporated into thecriteria. The criteria alsO have mandated that an accrediting association"encourage experimental and innovative programs." This requires that an

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accrediting association demonstrate that it is a change agent beforeit can be listed.

We believe that the Criteria have gone well beyond congressional intentand statute,' It was not, nor do we believe it is now, the intent ofCongress to grant to the Department of Education, through its Eligibilityand Agency Evaluation Staff, the authority to regulate directly the ac-crediting associations and therefore to regulate indirectly postsecondary 1

institutions. We are hopeful that steps can be taken to deal with theseconcerns which affect not only the accrediting associations, but all ofpostsecgndary education as well.

4, Do you feel that there should be any role for the Federal government inaccreditation?

There shoyld be no''ole by the Federal government in the accreditation ofinstitutions. Our colleges would support no move in this direction. Thecurrent role of the Department of Education in listing recognized accredi-ting associations shbuld be modified to allow increasing reliance on therecognition process of the Council on Postsecondary Accreditation and toreduce the inappropriate expansion of the criteria for recognition.

5. Now many schools that apply for accreditation through your associationreceive it? Now many schools lose accreditation during your review process?

If we assumed that there were no regional accrediting association in theSouth we could he certain that the number of postsecondary institutionswould be far more numerous than is currently the case. Many institutionsnever reach the nascent stage because of accrediting requirements whichexist down the road and without which accredi.tation the institutionwould have a difficult time attracting students, This is the initialscreening device.

Ongoing institutions that apply for accreditation have in many cases beenin existence some time and have gone through a development stage. Someof these (medical colleges, art colleges, seminaries, bible colleges,business colleges, for example) may already have accreditation throughanother accrediting agency. When institutions contact us concerningaccreditation they may receive advice which indicates'that they are notready to apply,

. .

These factors serve somewhat as screening devices so that, of the institu-tions which actually-do apply, the great majority eventually earn accredita-tion. The candidate stage, befog accreditation, offers an institution anadditional opportunity to correct weaknesses. Institutions may remain incandidate status up to six yea s.

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There are very few institutions which lose their accreditation duringthe review process. Quite a few institutions are placed on notice orprobation and most manage To correct deficiencies cited during the reviewprocess. Only one institution was dropped from membership during thelast few years and it was reinstated in probationary status after anappeal.

e.

Gordon W. SweetExecutive DirectorCommission oirCollegesSouthern Association of Colleges and SChools

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iNorth Control Assoclolion 159 Norin Dearbornof Collogoi and Schools C1r.earro. rerno:g 6060)

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March 2, 1983

Representative Paul Simon, ChairmanSubcommittee on Postsecondary EducationHouse of Representatives320 Cannon House Pff ice BuildingWashington DC 20515

Dear Representative Simon,

Thank you for the opportunity to testily before your committee on February 10, and toprovide, further information in'responselio your questions received on February 25.

For convenience 1 have provided responses to the questions on separate sheets, which areenclosed. 1 would of course be glad to provide any f:urther information that might bedesired by you or your committee.

1 appreciate your 'courtesy and the cordial interest of the committee during mytestimony. Please let me.know if additional information is desired.

Youi3?incerely,

Thurston E. MarraDirector of the Cornissionon Institutions of Higher Education

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Itespooses to Questions from theticxisee Subcommittee nn Postsqt:onthry Educationti .

Thurston E. Manning.Director of the Commission on Institutions of Higher EdUcation

North Central Association of colleges and &tools159North Dearborn. Chicago IL 60601

March 2, 1983 ti

Note: The responses represent the pvrsonal views of the responder, and are not officiallyapproved statements of the Nurth:Central Association of Colleges and Schools.

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1. Do you feel that special program accreditation (excluding professional schools) isnecessary or appropriate even though your association has already accredited theInstitution'?

Response:

Yes. Program accreditation provides a detailed examivation of an individualprogram, which is not provided by institute pal accreditation. Such detailedexamination is important for programs training practitioners for fields bea ing onpublic health and safety (for example, intdical technicians trained ,in co unitycolleges). Program examination can also be helpful to institutions that wisirtheexternal consultation provided in the field; while it is possible that an institutioncould arrange for its own examinations, having an evaluation program readilyavailable saves time and money for an institution and also gives better assurance of athoUghtful evaluation than does an ad hoc arrangement.

When the Federal government, has provided funding for specific programs (or forstudents in specific programs) it is appropriate for it to require such programs tomeet the specibl standards of program accreditation.

4he difficulties institutions have experienced with program accreditation fall intothree principal areas: First, on occasion program accrediting standards have beenrigid and rigidly applied, inhibiting or preventing useful innovations by individualinstitutions: Stcond, when state statutes and regulations require graduation from anaccredited program for licensurr of individual practitioners an institution cannot

. depart from the specific standards of the program accrediting body, even if theinstitution believes departures to be desirable. Third, the increase in tl)eflurober ofprograms sebject to accreditation has placed a burden on institutions. The Council onPostsecondary Accreditation has undertaken work in these areas, ancl I am hopefulthat appropriate relief occur:,

2. Dr. Ambach testified that he feels state accreditation is a viable ac'.ivity. Do youbelieve there is ever a need for the stafes to establish approval processes?

Response:

Yes. There are two distinct needs to be served by state approvals:l.

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The first is establishicag a minimum acceptable level for the operation of educationalinstitutions within a state. Since accreditation is voluntarily sought by institutions itcannot speak abealt the operations of institutions that do norseek accreditation. Thereasonable protection of c,itizeu from unscrupulous operations is a legitimateactivity of the state, and it is appropriate for a state to establish and enforce through

' its police powers.minimum requirements to,be met by.all institutions, whether or notthey seek accreditation. In my opinion, some .states go well beyond providing such.basic consumer protection, and., impose--requirements that .inhibit or preventreasonable variety,in institutional operations sometimes to the benefit of in-stateinstitutions and to the detriment of citizens who are thereby denied the benefits ofalternative educational institutis or programs. Some believe that no special,r,Rcuirements f9r educational institutions are needed, since statutes dealing withfraud and misrepresentation can be used to drive out undesirable operations. Thereare exarOles of effective use of sudi E atutes, but in general states have been slowto utilize them against shady educational operations.

The second need arises when the state provides substantial financial assistance toprivate institutions or students. In such.cases (the State of New York is a primeexample) it is approprlate for the state to establish additional reasonable institutionaland program requirements for access to state financil assistance.

States obviously have a concern, for coordination of state-operated colleges anduniversities, but this coordinating activity should be distinguished from approvalsrequired of all institutions, private and public.

3. Can you giv.e us some examples of Federal criteria for accrediting agencies that youobject to? 4.

Response:

No. %bile the wording and organization of the criteria could be improved, I findnothing in their content tilat should be objectionable to a well-run accrediting. body.It the Federal government is to rely on the decisions of accrediting bodies it isappropriate for it to have assurance that those accrediting bodies conduct theiractivities

4. Do you feel that there should be any role for the Federal government in accreditation?

Response:

Yes. ,The present Federal role of using accreditation as a threshold requirement forfunding eligibility is highly desirable, and the associated role -- examining accreditingbodies against reaamahje criteria to help insure that the accreditation meets theFederal eligibility need' is appropriate. The Federal government also provides,through the Fund for the Improvement of Postsecondary Education, a funding sourcelac improvement of accreditation; (FIPSE is currently funding a joint projet of the`Council for Postsecondary Accreditation arld the State Higher Education ExecutiveOfficers organization directed at providing to accrediting and state approval bodiesassistance needed in dealing with institutions operating at many locations through theuse of modern telecommunications.

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believe it is inappropriate for the Federal government to take a direct role inaccreditation, either by itself undertakingaccrediting activities, or by providing anapproval of accrediting bodies beyond that directly needed for Federal purposes.

5. How many schools that apply for accreditation through your association receive it?How rrony schools loft accreditation during your review process?

Itesponset

Data responding to these questions need to be interpreted in the light of our.practice. "Applying" for accreditation is not simply a matter of sending in someinformation. We regard the submission of a completed institutional self-study,.document as the formai application. The following steps outline the process;.notethat there are several steps before an application for accreditation is made:

.a. The institution provide's for staff analysis written materials bearing on whether

the institution meets North Central's General Institution 1 Requirements.

Between March 1, 1982, and February 28, 1983, e receivrA influiriesfrom 101 institutions and responded by providing ach with the GeneralInstitutional Requirements (and other infccmation). Only about a third ofthose inquiring have responded by filing information about theiractivities. In fairness to the inquiring institutions it should be said that,judging from Their names, a number are short-course vocational

'institutions that fall outside the Corrunission's scope, and in several casesinformation was requested for use in assessing whether to Organize a newinstitution.

b. Unless the staff analysis shows a prima facie case that the institution meets the.General Institutional Requirements no further formal action is taken, but inmany cases institutions seek informal staff counsel in revising their activitiesand materials.

Of the 39 institutions that have submitted information, 16 have beenfourxi to make this prima facie case. The other 23 have been requested to

jprovide further information, have been advised that unless changes aremade in their operations they do not appear to meet the Requirements.

'c. Following staff acceptance of the written submission, the institution is advisedto ptoceed with a self-study, and assistance is given in this process.

Of the 16 institutions receiving staff acceptance, 10 have submittedself-study documents, and 6 are in the process of self study.

d. Following receipt of the self-study document, which constitutes the formalapplication for consideration, the Commission's evaluation process, including asite visit by a team, is scheduled.

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Of the 10 institutions submitting self-study documents (and therebyformally applying for affiliation), 5 have site visits scheduled after March1, 1983. Actions have been taken on the remaining 5 as follows:

One was granted accreditation (this is a long-established publicvocational-technical school that had not previously sought NorthCentral affiliation); ,

Two were granted candidacy;

One was denied candidacy;

One withdrew its application following the site visit and review, butbefore final qoinrnission consideration.

e. The common path to accreditation is for the institution first to seek tandidacy,a lama{ status of affiliation with North Central. An institution can be incandidacy for six years; candidate institutions are evaluated through a site visitevery two years. Institutional development during the candidacy years points toaccreditation, and in general a candidate institution successfully attainsaccreditation. o

Of the 14 institutions granted accreditation during the past year, 8 movedto accreditation from candidacy; the 6 granted accreditation withoutcandidacy were all long-establishes institutions (four of them theologicalseminaries) that had not previously 5°4,0 North Central affiliation. 6

candidate institutions that applied for accreditation were deniedaccreditation but had candidacy continued. tinder Commission policy aninstitution can withdraw an application for accreditation or candidacywatiout prejudice at any time before the final decision; sonic candidate'institutions that originally sought accreditation withdrew the applicationin the course' of the process and successfully sought continuation ofcandidacy. 10 institutions were granted candidacy. (Note: these numbersdiffer from those in paragraph d. above because actions enumerated hereinclude institutions making application before March 1, 1982.)

f. During the past year the Commission has withdrawn accreditation from oneinstitution on probation (which then ceased operations), and has withdrawncandidacy from one institution (which is in the process of appealing from thisdecision). One institution, which had been placed on probation, merged with astrong institution. The Commission seeks to counsel institutions in difficultcircumstances to 'find additional resources, merge, or cease operations beforeconditions have deteriorated to the point at which accreditation or candidacywill be withdrawn.

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oMarch 7, 1983

The Honorable Paul SimonHouseopf Representatives

3O Cannon House Office BuildingI Washington, D.C. 20515

Dear Congressman Simon:

Ace:wining Commission

«."

*0 This is in response to your letter of February 23, 1983, invitinganswers to three specific questions, with the responses to be in-

P eluded in the record of the hearing held before the Subcommitteeon,Fostsecondary Education on February 10, 1983. We are happy to

2 respond.

Please note for your files that your letter wan sent to the wrongassociation and the wrong address and was delayed in reaching ouroffice, which is m indicated on this letberheed.

1. The AICS accrediting process involves a continuousmonitoring of the fiscal stability of an inktitution.An annual "accounting-type" finenciel repoit isrequired filing. Tile information submitted rs cornputerized 'and the data are analyzed. The data arethen compared to similar data from the institutionfor previous years. If the potential for fiscal in-stability shows up, the institution then is requiredto submit quarterly financial statements and the

(1 monitoring intensifies until the institution eitherrecovers its stability or has its accreditation with-

o drawn for fiscal instability.

I would like to point out that your reference,to"o* "default rates on student loans" is'rather broad

and seems to imply an institutional responsibilityO for the collection of all "student loans." This isa not the cane. For the moat part, AICS accredited

institutions participate in two loan programs, theNDSL program and the CSI, program. Whip there is aninstitutional responsiblity in the collection of

oNDSL's, the same is not true for USL's, the collee-n

O . tion of which in out of the hands of the partial-gating institution.

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Default rates on student loana are only one of manyfactors that affect the overall financial stabilityof an institution. I cannot recall an institutionever losing its accreditation solely based on the

. default factor -- except as that factor, perhapswith others, reflects the administrative capabilityor educational quality at an institution end whichthe lack of, in the opinion of the Accrediting Com-mission, has led to loss of acoreditation by numer-ous institutions.

.There le dissuasion within the Commission at thistime about the development of guidelines to aidsite evaluators and staff members in better al-seeeing the financial aid management at an insti-tution. It would not be the intent of thhseguidelines to transform evaluators into auditors,rather to help them identify financial aid

edministration weaknesses at an institution andto report those weaknesses to the AccreditingCommission.

2. During 1982, a total of 58 institutions werereviewed for initial accreditation. Of these,36 received accreditation, a percentage of 62.(It is instructive to understand that a highpercentage do not achieve accreditation on firstattempt, but continue to remedy deficienciesuntil they are accreditable. An initial appli-cant institution may be deferred one or moretimes while remedying deficiencies before ac-creditation is either granted or denied. Thisprocess can take a full 12 months or longer.)

During 1982, accreditation was removed forvarioue causes from ten institutions. (Severalother suspensions issued in 1982arepesding,while schools exercise their appeals.) ---

3. Only those relatively few states that claim tohave constitutional responsibility for accredi-ting should be engaged in a process whichduplicates what the accrediting associations

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already do. There is an admitted role forstates tit the lfcenning or approval of propri-etary schools to operate. To protect consumerinterests in that area requires far less ad-ministrative detail and academic evaluation thandoes accreditation, however.

As a matter of routine, AICS invites appropriatestate officials to be present during site evalu-ations and to share with the Aocrediting Commis-Bien-any-information they-wish to about a giveninstitution. State officials, on the other hand,do not routinely notify accrediting bodies oftheir inspection activities and, generally, itis our experience that only when an institutionis in some sort of trouble that results in pub-licity do state officials feel obligated to bein touch with accrediting organizations%

I trust the foregoing ilk responsive to your questions and will behelpful to The Congress.1 Thank.you for the opportunity to partici-pate in helping.to shape legislation.

Sincerely,

4F-AX0.77),

James M. PhillipsExecptive Director

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OUCSTIOS FO DR. JAMES PHILLIPS

1. DURING YOUR ACCREDITATION AND REVIEW PROCESS, DO YOU

EVALUATE THE FISCAL RESPU9SIB/LITY SHOWN BY INSTITUTIONS .

SUCH AS DEFAULT RATES ON STUDENT LOANS? DO SCHOOLS EVER

LOSE ACCREDITATION FOR THAT REASON?

2. CAN YOU GIVE US A PERCENTAGE ON HOW MANY SCHOOLS THAT

APPLY FOR ACCREDITATION RECEIVE IT? HOW MANY SCHOOLS

LOSE ACCREDITATION DURING YOUR REVIEW PROCESS?.

3. DO YOU FEEL THERE SHOULD BE ANY ROLE FOR THE STATES IN

ACCREDITING AND REVIEWING INSTITUTIONS? DOES AICS EVER

WORK WITH STATE FEVIEWERS AT INSTITUTIONS?

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Ho A WonkyAdeorausta

Aare Monk*Aeon. Assuan

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ACCREDITING BUREAU OF HEALTH EDUCATION SCHOOLS(Formerly Accrediting lima Or Mod Icei Liftman, Sefton)

Oak Manor Offices 29089 U. S. 20 West, Elkhart, Indiana 48514.1198

Telephone: AC 219 293.0124

February 21, 1983

Honorable Paul SimonChairmanSubcommittee ou Postsecondary EducationHouse Committee on Education and Labor320 Cannon House Office BuildingWashington, D.C. 2031S

Dear Mr..Chainmn

nap Lewis. Ed.O.

Cower!

Mary Lou AndUnite),

We would like to submit the following information for inclusion in the

record of the Subcommittee Hearings of February 8-10, 1983.V

The hearings which focused on the Carnegie Foundation Essay, The Control

of the gave inadequate recognition to the functions of specialized

accreditation and its basic importance to the fields in which it operates.

In addition, the presentations made at the hearings were almost exclusively

dissertations from the higher plucation.comnunity and did not truly0

represent the problems and contributions of the private and proprietary

institutions offering occupational education and training_for_immedia.te

entry level employment and advancement.

Department of Labor statistics indicate that there will be shortages of

trained personnel to serve the Allied Health fields for the foreseeable

future. Yet, a major resource to alleviate this grave societal need is thegp

private and proprietary schools offering current and updated courses in the

essential areas.

These institutions are tax-paying businesses whose success and continuity

depend upon their effectiveness and the success of their graduates in

INDEPENDENT ACCREDITING AGENCY OF THE AMERICAN MEDICAL TECHNOLOGISTS

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obtaining employment and becoming self sustaining members of tar society.

The many levels mid types of training nuke it possible for those with little

or with adequate background to succeed at approntlate levels.

Iloyites in the health field 'mist assume important tesponsibilities in their

work in hospitals, clinics, doctors' offices and in lesting.laboratories. It

. is incumbent on' them to know current tecliMques and nractices to safely and

efficiently serve the public. Private and proprietary schools are organized

to respond quickly and appropriately in mikir curriculum modifications and

to upthitv practices - an activity which is not nearly as effective in the

, traditional higher education institutions. A basic reason for this advantage

is that many of suchofferings.have specialized accreditation with attendant

standards and criteria which are uglated continuously as the fields demunhl.

Since mention of the operation. and activities of the Accrediting Nireau of

Health Education Schools was not specifically identified in the Carnegie Report

and in the hearings, and since this agency has operated nationally to serve

its memiwr schools for more An fourteen years,, its record shoo d he brought

to:the attent ion of persons concerned with the hearings.

Acciol)Fr I NG BUREAU OF III:AI:HI EIRICAT ION SCHOOLS

AilHES was initially recognized by the U.S. Office of Education as a national

accrediting agency in 1909 (just one year after the activities of the Accreditation

and lntititut'inn.il 11 ig ib i 1 i ty Staff comenced operation). lbe Bureau has

received continuing and expanded scope recognition to the present date. In the

specialised area, AMES dedicated its efforts to the development and implementa-

tion of standards and guidelines for schools offering education and training

fa Medical Laboratore Technicians and fur Medical Assistants. All during this

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period of some feurteen*years and cyclic reassessment and continued recognition

of the Bureau, the U.S.O.E. and subsequently the Department of Education

extended effective, incisive cild appropriate guidance and assistance to

MILS. Moir r6quirements were and are clear and definitive and their

decisions have been fall: mid equitable.

Although MIES is also recognized by COPA for the two specialized areas In

the private and proprietary sectors, this organization is still in a growth

and development stage. The Bureau was one of the first agencies to he

processed for recognition by.COPA and is in a p-sitien to assess the organization

in a constructive way. Its predecessor organizations NCA and FRAME were of

limited duration and NCA was not kindly disposed toward private and Proprietary

,.schools because of its orientation toward higher education nersnectives. At .

present, °IPA has two assemblies to represent specialized and inlititutional

lcereditation interests. But this doe 4 not yet serve their constituent members

since some accredit both institutional and specialized. It would by

unwarranted at this time to seriously curn;ider that CODA take over the function

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to determine eiCgibility of institutions to particinate in Federal Programs.

The system in place has generally worked very well. What COPA could do is an)

unknown which we cannot afford to test at a time when. fOP.\ is still in a

developmental phase,

ABMS has grown to a noint where it now has in excess °Cone hundred schools

and prutrams on its accredited list. Over the years nrograms have been

dropped from the list for newcompliance itith essential standards. In no case,

however, has there ever been a law suit instituted against the Bureau as a result

of the decisions of its commissioners. On the other hand, support from our

member schools has been outstanding to encourage expanded scope activities.

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As a result, ARI1[S was further recognized in June-I9t12 to aCcredit institutions

offering.allied'health education in the private and Proprietary sectors.9

'All of our schools and programs are eligible for funding under appropriate

mograms. As a result, thirBureau's Visitation Teams also. assess the

financial practIcest of the applicant schools aad programs for soundness*:nuk,

stability, In addition, Annual Repotkpom the schools arc received by the0

and are reviewed for continuing compliance.with financial and other

requirements. In 19:42 the GSA conducted audits of the schools of a inaier

of 1)li-rec6gnized accrediting agencies. Apms and its member schools received

a clean bill-of-health relating to its practices.

the Bureau reviews placement services, employment documentation of graduates,

assessment it...ports of proficiency of graduates from employers, and dropout

rates to inAiru that students are being well trained and Aro successful in

their work. In,addition, the Nknnhils of the Bureau, which contain criteria,

guidelines and requirements for accreditation of schools and programs, are

revised and disseminated every two years.with interim supplements as appropriate.

As a result, the practices and procedure employed in our accredited scheols, are

kept current and reflect desirable innovative Procedures in the appropriate

areas.

It was noted that Secretary Bell mentioned that the Carnegie Report was under

study in his pepartment and that a report with reconuendations would he

forthcoming ,it the conclusion of this rev:ow. in the event that further

hearings are TO be scheduled in the future, ARIllS would he pleased to prpa,

a presentation that would equitably represent the case of specialized education,

particularly the offering of the private and proprietary schools.

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ANITIONAL COMMENTS

1. The services of AMES for private and proprietary schools and programs in

the health education field is essential since the Bureau is conceyned

with and serves their highly-differentiated needs, which are different

Din many respects to the. character of higher education offerings per se.

2. We are at a loss to understand why specialized accreditation was not, in

balance, represented at the hearings.

3. The schools we serve prepare graduates for entry level jobs in areas'..

%%here there are jobs, and the courses are, tailored to the requirements

of the training objectives - not necessarily to fit intu traditional time

slots.

4. The Bureau's criteria for accrediting schools and programs are eqqiil to

and in many cases more stringent than those implemented in institutions

of higher learning.

5. Since accreditation is voluntary, there is no "intrusion on campus."

Application for ABMS accreditation must be made at the option and

decision of the administration of the school or program.

CONCLUSIONS

1. The Secretary of Education should'not use regional accreditation as the

basis for eligibility for Federal Programs. Regionals have different

criteria which do not and cannot equitably apply to our schools/programs,

Sane accredit programs "at least one academic year in length." Others

specify, "colleges that offer baccalaureate degrees," Mother example

stresses, "institutions that award bachelor's, masters, or doctor's

degrees, and two-yearipinstitutions which include in their offerings degrees

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in libelal arts or general. studies." And the list goes on. None-of

these nattew. are anpropriate'for the private and nroprietary schools.

lieconinending that CODA and not the Secretary of Education prePare the

list,pf regional associations is impractical for many reasons including, ....

the fact 'that regionals are noCexperienc.ed or prepared to assess

specialized programs.

. COPA should not he .the place o( final appeal between accrediting agencies

and their accredited institutions. Thi would merely further complicate

rather than sinplffy the process. As mentioned earlier, AMPS has been

able to rosolVe iinref its problems without recourse to liti;atiun.

47:4.-t

4. A thorough hearing of the place and activities of the private and

proprietary schools will revealing and will substantiate the need for-

recognition of the impoi!int contributions of this facet of the educational/

training process.

a?"I lug}t%i. Woosley

Administratorfor

API Colin issi nn

HAW:mlr

104CC: Pager D. liarrv, Ph.D., AIMS Chainmin

Nniald J. Bove, Ph.D., ABIlfS VicePhilip Lewis7'Ed.D., ARMIES ConsultantThomas R. Jolly, Esquire, ARMS Legal CounselChristina Fleps, Attorney, AB MS Legal CounselCODA

0

21,3

14 st41.11.).

I